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United States 
Environmental Protection 
Agency 


Office of Air Quality 
Planning and Standards 
Research Triangle Park, NC 27711 


EPA-453/R-01-008 
September 2001 


Background Information Document: 
National Emission Standards for 
Hazardous Air Pollutants (NESHAP) 
for the Friction Materials 
Manufacturing Industry r, q 



















EPA-453/R-01-008 


Background Information Document 


National Emission Standards For 
Hazardous Air Pollutants (NESHAP) 
for the Friction Materials 
Manufacturing Industry 


Emission Standards Division 


U. S. Environmental Protection Agency 
Office of Air and Radiation 
Office of Air Quality Planning and Standards 
Research Triangle Park, NC 27711 


September 2001 


This report has been reviewed by the Emission Standards Division of the Office of Air Quality 
Planning and Standards, EPA, and approved for publication. Mention of trade names or 
commercial products is not intended to constitute endorsement or recommendation for use. Copies 
of this report are available through the Library Services Office (MD-35), U. S. Environmental 
Protection Agency, Research Triangle Park, NC 27711. (919) 541-2777, or from National 
Technical Information Services, 5285 Port Royal Road, Springfield, VA 22161, (703) 487-4650. 




lC Control Numbe' 



2003 426119 


I3W-1 VS» 























Table of Contents 

Page 

LIST OF FIGURES .vi 

LIST OF TABLES. vii 

LIST OF ACRONYMS AND UNITS OF MEASURE.viii 

1.0 INTRODUCTION .-..1-1 

1.1 Statutory Basis....•.1-1 

1.2 Source Category Listing .1-3 

1.3 References . . 1-4 

% 

2:0 FRICTION MATERIALS MANUFACTURING SOURCE CATEGORY.2-1 

2.1 Industry Profile .,.2-1 

2.1.1 Data Gathering .2-2 

2.1.2 Industry Overview.2-3 

2.1.3 Major Sources.2-5 

2.1.4 Source Types Not Regulated.2-6 

2.1.5 SIC and NAICS Codes.2-7 

2.1.6 Small Businesses.2-7 

2.1.7 Markets.2-9 

2.2 Resin-Based Friction Materials Manufacturing Process.2-10 

2.2.1 Raw Material Preparation.2-13 

2.2.2 Forming.2-14 

2.2.3 Curing.2-14 

2.2.4 Assembling and Finishing.2-15 

2.3 Characterization of HAP Emissions from Resin-Based Friction Materials 

Manufacturing Emission Units .2-15 

2.4 Emission Test Data. 2-17 

2.5 Existing State Regulations.2-17 

2.6 References.2-18 

3.0 EMISSION CONTROL TECHNIQUES..3-1 

3.1 Condensers . 3-2 

3.1.1 Factors Affecting Performance.3-3 

3.1.2 Control Efficiency.3-4 

3.1.3 Current Monitoring Practices .3-5 

3.2 Carbon Adsorbers .3-6 

3.2.1 Factors Affecting Performance.3-9 

3.2.2 Control Efficiency.. 3-11 

3.2.3 Current Monitoring Practices .3-11 

3.3 Pollution Prevention Techniques.3-12 

3.4 References.3-13 

4.0 MACT FLOOR AND REGULATORY OPTIONS. 4-1 


m 








































Table of Contents (continued) 

Page 

4.1 Clean Air Act Requirements.4-1 

4.2 MACT Determinations .4-2 

4.2.1 Performance of Solvent Recover> Systems on Solvent Mixers.4-2 

4.2.2 Selection of MACT.4-5 

4.2.3 Selection of the Standard .4-9 

* 4.3 Monitoring Options.4-9 

4.4 References.-.....4-12 

5.0 MODEL PROCESS UNIT.5-1 

5.1 General Approach .5-1 

5.2 Solvent Mixers . % .5-2 

5.2 References.'.5-3 

6.0 ENVIRONMENTAL AND ENERGY IMPACTS .6-1 

6.1 Basis for Impacts Analysis .6-2 

6.2 Primary Air Pollution Impacts.6-2 

6.3 Secondary Air Pollution Impacts.6-3 

6.4 Water Pollution Impacts .6-5 

6.5 Solid Waste Disposal Impacts.6-5 

6.6 Energy Impacts .6-5 

6.7 References.6-6 

7.0 COST OF CONTROLS .7-1 

7.1 Basis for Control Cost Analysis .7-2 

7.2 Control Device Costs.7-4 

7.3 Initial Compliance Costs.7-5 

7.4 Monitoring Costs.7-5 

7.5 Reporting and Recordkeeping Costs.7-5 

7.6 Cost Effectiveness.7-6 

7.7 New Sources .7-7 

7.8 Small Businesses. 7-7 

7.9 References.7-7 

APPENDIX A. EVOLUTION OF THE STANDARD . A-l 

APPENDIX B. EMISSION ESTIMATION METHODOLOGY.B-l 

B.l Plant A.B-l 

B.1.1 Baseline and Uncontrolled Emissions.B-l 

B.1.2 MACI Floor and Beyond-the-Floor Emissions.B-2 

B.2 Plant B .B-2 

B.2.1 Baseline and Uncontrolled Emissions.B-2 

B.2.2 MACT Floor and Beyond-the-Floor Emissions.B-6 

B.3 Plant C .B-6 


iv 









































Table of Contents (continued) 

Page 

B.3.1 Baseline and Uncontrolled Emissions............B-6 

B.3.2 MACT Floor and Beyond-the-Floor Emissions.B-8 

B.4 Plant D..B-8 

B.4.1 Baseline and Uncontrolled Emissions....B-8 

B.4.2 MACT Floor and Beyond-the-Floor Emissions.B-8 

* B.5 References .B-9 


v 













List of Figures 


Page 

Figure 2-1. Geographic distribution of friction products manufacturing facilities.2-3 

Figure 2-2. Simplified process flow diagram for the manufacture of brake shoes 

and strip lining . 2-11 

Figure 2-3. Simplified process flow diagram for the manufacture of disc brake pads 

and pucks .2-12 

Figure 3-1. Typical shell-and-tube condenser ..3-2 

Figure 3-2. Typical stationary-bed, regenerate carbon adsorption system .3-8 


vi 








List of Tables 


Page 

Table 2-1. Friction Products Manufacturing Processes.2-4 

Table 2-2. Distribution of SIC Codes Reported in ICR Responses for Major Sources in the 

Friction Materials Manufacturing Source Category.2-8 

Table 2-3. Small Business Association Cutoffs for SIC Codes Reported by Major Sources . 2-8 

Tftble 2-4. Distribution of Product Market Segments for Major Sources .2-9 

Table 2-5. Distribution of Product Type for Major Sources .2-9 

Table 2-6. Reported 1996 Production and Capacity for Major Sources .2-10 

Table 2-7. Potential and Baseline \nnual HAP Emissions from Friction Materials 

Manufacturing Major Sources .2-16 

Table 3-1. Condenser Operating Parameters Reported in ICR Responses .3-4 

Table 3-2. Summary of Performance Indicators for Condensers.3-5 

Table 3-3. Condenser Monitoring Procedures Reported in ICR Responses .3-6 

Table 3-4. Summary of Performance Indicators for Carbon Adsorbers .3-11 

Table 4-1. Existing Control Technologies for Potential Sources of Organic HAP Emissions 
at the Four Major Source Facilities in the Friction Materials Manufacturing 

Industry.4-3 

Table 4-2. Summary of MACT Determinations .4-5 

Table 4-3. Summary of Monitoring Options for Solvent Mixers at Friction Materials 

Manufacturing Facilities.4-11 

Table 5-1. Exhaust Stream Characteristics for Closed-Vent Solvent Mixer Systems.5-3 

Table 5-2. Model Process Unit Exhaust Parameters for Closed-Vent Solvent Mixer Systems 5-3 

Table 6-1. Nationwide Primary Air Impacts for Existing Friction Materials 

Manufacturing Facilities.6-3 

Table 6-2. Nationwide Secondary Air and Energy Impacts for Existing Friction Materials 

Manufacturing Facilities.6-4 

Table 7-1. Assumptions for Annual Cost Calculations.7-3 

Table 7-2. Control Costs for Condensers Installed on Individual Solvent Mixers .7-4 

Table 7-3. Nationwide Cost-effectiveness for Existing Friction Materials Manufacturing 

Facilities.7-6 

Table A-l. Evolution of the Standard. A-l 

Table B-l. Facility-Specific Uncontrolled HAP Emissions.B-3 

Table B-2. Facility-Specific Baseline HAP Emissions .B-3 

Tab ~ B-3. Facility-Specific MACT Floor HAP Emissions.B-4 

Table B-4. Facility-Specific Beyond-the-Floor HAP Emissions .B-4 



























List of Acronyms and Units of Measure 


BID 

Btu/lb 

CAA 

CFR 

CO 

CRF 

EfA 

gal 

HAP 

ICR 

lb 

lb/gal 
MACT 
M MB tu 
mm Hg 
NAICS 
NESHAP 
NO x 
NSPS 
"NTI 
OAQPS 
PEC 
PM 
PM 10 
ppm 
SBA 
SIC 
S0 2 
TCE 

tpy 

TRI 

VOC 


background information document 
British thermal unit(s) per pound 
Clean Air Act 

Code of Federal Regulations 

carbon monoxide 

capital recovery factor 

U.S. Environmental Protection Agency 

gallon(s) 

hazardous air pollutant 
information collection request 
pound(s) 

pound(s) per gallon 

maximum achievable control technology 
million Btu 

millimeter(s) of mercury 

North American Industry Classification System 
national emission standards for hazardous air pollutants 
nitrogen oxides 

new source performance standards 

National Toxics Inventory 

Office of Air Quality Planning and Standards 

purchased equipment cost 

particulate matter 

PM with an aerodynamic diameter at or below 10 micrometers 

part(s) per million 

Small Business Administration 

Standard Industrial Classification 

sulfur dioxide 

trichloroethylene 

ton(s) per year 

Toxics Release Inventory 

volatile organic compound 


vm 


* Chapter 1 

Introduction 

The purpose of this back-ground information document (BID) is to summarize the background 
information gathered and the analyses performed during the development of the proposed friction 
materials manufacturing national emission standard for hazardous air pollutants (NESHAP). This 
chapter presents the statutory basis for the NESHAP, and a discussion of the source category 
listing. Chapter 2 characterizes the friction materials manufacturing industry, including an industry 
profile, process description, characterization of organic hazardous air pollutant (HAP) emissions, 
and a summary of existing State regulations applicable to friction materials manufacturing 
facilities. Chapter 3 describes organic HAP emission control techniques that are currently being 
used at friction materials manufacturing facilities and discusses pollution prevention options for 
reducing air emissions of HAP. Chapter 4 describes the rationale for the determination of 
maximum achievable control technology (MACT) floors, regulatory options for specific segments 
of the friction materials manufacturing industry, and compliance assurance monitoring options. 
Chapter 5 describes the model process units developed to evaluate the effects of the various 
control options. Chapter 6 presents estimates of primary air impacts, secondary' environmental 
impacts, and energy impacts for existing sources resulting from the control of HAP emissions 
under the proposed standards. Chapter 7 presents the cost of applying the control options and 
monitoring required to meet the MACT standards and to ensure continuous compliance. 

1.1 STATUTORY BASIS 

Section 112 of the Clean Air Act (CAA) requires the U. S. Environmental Protection Agency 
(EPA) to establish technology-based emission standards for all categories and subcategories of 
major and area sources emitting one or more of the HAPs listed in §112 (b) of the CAA. These 
NESHAP must represent the MACT for all major sources. Additional standards may be 


1-1 


developed later under §112 (f) of the CAA to address residual risk that may remain even after 
application of the.technology-based controls. Section 112 (a) of the CAA defines a major source 
as: 

. . any stationary source or group of stationary sources located within a contiguous area 
and under common control that emits or has the potential to emit considering controls, in 
the aggregate, 10 tons per year or more of any hazardous air pollutant or 25 tons per year 
or more of any combination of hazardous air pollutants.” 

% 

Potential to emit is defined in Part 70 of the Code of Federal Regulations (CFR) as, .. the 
maximum capacity of a stationary source to emit any air pollutant under its physical and 
operational design.” Part 70 of the CFR further explains that, .. any physical or operational 
limitation on the capacity of a source to emit an air pollutant, including air pollution control 
equipment and restrictions on hours of operation or on the type or amount of material combusted, 
stored, or processed, shall be treated as part of its design if the limitation is enforceable by the 
Administrator.” / 

An area source is defined as “. . . any stationary source of hazardous air pollutants that is not a 
major source.” The regulation of area sources is discretionary. If there is a finding of a threat of 
adverse effects on human health or the environment, then the source category can be added to the 
list of area sources to be regulated. 

The Clean Air Act Amendments of 1990 prescribe an analytical framework that EPA is to apply in 
developing NESHAP for major sources. A key concept in this framework is the establishment of 
the MACT floor. Section 112 (d) of the CAA specifies that NESHAP for existing sources are to 
be no less stringent (but may be more stringent) than, “. . . the average emission limitation achieved 
by the best-performing 12 percent of the existing sources (for which the Administrator has 
emissions information). . .” for categories and subcategones with 30 or more sources. For 
categories or subcategories with fewer than 30 sources, the MACT floor cannot be less stringent 
than the average emission limitation achieved by the best-performing 5 sources. The MACT floor 


1-2 


for new sources cannot be less stringent than the level of emission control that is achieved in 
practice by the best-controlled similar source. 

A second key feature of the NESHAP development process is that of determining subcategories. 
Section 112 (d) of the CAA allows the EPA Administrator to, . . distinguish among classes, 
types, and sizes of sources within a category or subcategory in establishing such standards. . . 

The effect of this provision is thai for each-category or subcategory for which EPA is developing 
NESHAP, the resulting standards could be tailored to account for significant differences in 

classes, types, and sizes of sources. For each of the resulting classifications, a separate MACT 

% 

floor determination is required. 

1.2 SOURCE CATEGORY LISTING 

Section 112 of the CAA requires us to list all categories of major HAP emitting sources and to 
promulgate regulations for their control. An initial list of source categories and accompanying 
schedules for regulation were published on December 3, 1993 (58 FR 63941). 1 Friction materials 
manufacturing was not among the initially listed source categories. A subsequent notice published 
on June 4, 1996 (61 FR 28197) added friction products manufacturing to the list of major source 
categories scheduled for regulation by November 15, 2000. : The listing was based on information 
obtained in a 1992 survey of the industry from which we concluded that some facilities that 
manufacture friction products have the potential to be major sources of HAP emissions. Friction 
products manufacturing includes facilities that manufacture, assemble or rebuild friction products 
such as brakes, or clutches. Based on additional information obtained during the development of 
this proposed rule, we have determined that only facilities that manufacture friction materials have 
the potential to emit HAP at major source levels. As such, this proposed rule will affect only 
friction materials manufacturers. 


1.3 REFERENCES 

1. U. S. Environmental Protection Agency. National Emission Standards for Hazardous Air 
Pollutants Schedule for the Promulgation of Emission Standards Under Section 112(e) of 


1-3 


the Clean Air Act Amendments of 1990. 58 FR 63941. Washington, DC. U. S. 
Government Printing Office. December 3, 1993. 

2. U. S. Environmental Protection Agency. National Emission Standards for Hazardous Air 
Pollutants; Revision of Initial List of Categories of Sources and Schedule for Standards 
Under Sections 112(c) and (e) of the Clean Air Act Amendments of 1990. 61 FR 28197. 
Washington, DC. U. S. Government Printing Office. June 4, 1996. 



1-4 


Chapter 2 

Friction Materials Manufacturing 

Source Category 

% 

Friction materials manufacturing is a subset of friction products manufacturing. This chapter 
characterizes the friction materials manufacturing industry source category, including facilities, 
products, manufacturing processes, sources of HAP emissions, emission reduction techniques, and 
summarizes applicable State regulations. The sources of information presented in this chapter 
include the literature, industry representatives, site visit reports, information collection requests 
(ICRs), and State and local air pollution control agencies. 

Section 2.1 provides a profile of the friction materials manufacturing industry. Section 2.2 
describes the friction materials manufacturing process. Section 2.3 characterizes friction materials 
manufacturing HAP emission sources. Section 2.4 summarizes the available emission test data. 
Section 2.5 summarizes existing State regulations that pertain to friction materials manufacturing 
facilities. Section 2.6 contains a list of references. 

2.1 INDUSTRY PROFILE 

Broadly speaking, the friction products manufacturing industry includes any facility that 

manufactures or re-manufactures friction products such as brakes and clutches. A friction product 

« 

is defined as a device that uses friction to accelerate or decelerate a vehicle or moving element of 
a machine. Brakes use friction materials to slow, stop, or hold stationary a vehicle or machine 
part. Clutches use friction materials to transfer kinetic energy from a power source to a 
transmission to rotate wheels or equipment parts. 1 


2-1 


Brake friction products can be further subclassified according to design as one of the following: 

brake pads, as used in light vehicle disc brakes; brake linings, as used generally in light vehicle 

drum brakes; brake segments, which are strip linings used in medium-sized truck drum brakes; 

brake blocks, which are brake pads used in heavy duty truck and off-road vehicle drum brakes; and 

brake discs, as used in aircraft brakes. Brake pads that are manufactured and sold separately for 

aftermarket use also are referred to as pucks. 1 
* 

Clutches can be classified as wet or dry according to the type of transmission with which they are 

used. Dry clutches are used with manual or standard vehicle transmissions; vehicles with 

% 

automatic transmissions use wet clutches, in which kinetic energy is transferred through a viscous 
fluid. The friction material component of clutches is referred to as the clutch facing. 1 

2.1.1 Data Gathering 

In 1997, ICRs were mailed to friction products manufacturing facilities to obtain detailed process 
and emissions data in order to characterize the industry. These ICRs requested data for the 1996 
manufacturing year. Information collection request responses were received from 147 facilities 
(100 companies) that manufacture friction products in 34 states. These responses are believed to 
represent all of the friction products manufacturing facilities in the United States. Figure 2-1 
presents the geographical distribution of the 147 friction products manufacturing facilities 
identified in the project database. 

In addition, EPA conducted 11 site visits to 10 facilities in 7 states (including visits to 3 of the 
4 facilities estimated to be major sources). Telephone calls were made to many of the ICR 
respondents to clarify and/or complete ICR responses and to gather additional information. The 
EPA also contacted several State agencies, including Colorado, Georgia, Indiana, North Carolina, 
Tennessee, and Wisconsin, for permits and emission test data 

Industry information collected by the U. S. Census Bureau on the friction products industry is 
contained in the “Motor Vehicle Brake System Manufacturing 1997 Economic Census Report.” 2 
However, the data collected covers the manufacture of the entire motor vehicle brake system; 
friction materials manufacturing statistics are not specified. Additional U. S. Census Bureau 


2-2 



Figure 2-1. Geographic distribution of friction products manufacturing facilities. 


information on the transportation industry' in general is included in the Statistical Abstract of the 
United States. 3 

2.1.2 Industry Overview 

Based on a review of the ICR responses, the 147 friction products manufacturing facilities can be 
organized into three basic categories: assemblers, rebuilders, and friction materials manufacturers. 
Of the 147 friction products manufacturers, there arel6 friction products assemblers, 78 friction 
products rebuilders and 53 friction materials manufacturers. Of the 53 friction materials 
manufacturers, 2 facilities manufacture sintered friction materials, 4 facilities manufacture carbon- 
based friction materials, and 47 facilities manufacture resin-based friction materials. Table 2-1 
lists the manufacturing processes for which data were collected, provides the number of facilities 
for each process type, and lists the products manufactured with each process. During the review 
of the available information on this source category, we found that these types of friction products 




2-3 



























manufacturing facilities are generally different from each other with respect to types of raw 
materials, process operations, and emission characteristics. 


Table 2-1. Friction Products Manufacturing Processes 


Manufacturing process 

No. of facilities 

Product type(s) 

Assemblers 3 

16 

Brake shoes; disc pads; clutches 

&ebuilders b 

78 

Brake shoes; clutches 

Friction Materials Manufacturers 

Sintered 

2 

Brake discs; clutch facings 

Carbon-based 

% 

4 

Brake discs (aircraft) 

Resin-based 

47 

Disc brake pucks; disc brake pads; brake lining; 
brake segments; brake block; brake shoes; clutch 
facings; friction material 

Total 

147 

• 


a Assemblers purchase new friction material and attach it to new steel backing plates or shoes; no new friction 
material is manufactured at the facility. 

b Rebuilders purchase new friction material and attach it to reconditioned brake shoes or clutch plates; no new 
friction material i$ manufactured at the facility. 

Assemblers purchase new friction material from other manufacturers and attach it to new backing 
plates or shoes. Rebuilders purchase new friction material from other manufacturers and attach it 
to reconditioned brake shoes or clutch plates. None of these facilities manufacture friction 
material and none are major sources of HAP. Consequently, none of these facilities will be 
regulated under the friction materials manufacturing NESHAP. 

Friction materials manufacturers make brake and clutch linings, and in most cases assemble 
finished products. Friction materials manufacturers can be classified into three classes based on 
the friction material manufactured: sintered material, carbon-based material, and resin-based 
material. 

Two facilities manufacture sintered friction materials. Both use high-temperature sintering ovens 
to fuse the non-HAP metal and mineral ingredients into a consolidated product. Neither facility is 


2-4 




















believed to be a major source of HAP, and, therefore, neither will be regulated under the friction 
materials manufacturing NESHAP. 

Four facilities manufacture carbon-based friction materials in which carbon is impregnated into a 

synthetic mesh to create a friction material. Hydrogen cyanide is the only HAP known to be 

eQiitted from this process. All four existing facilities have Federally enforceable control 

requirements that limit hydrogen cyanide emissions to well below the major source threshold of 

10 tons per year (tpv). In addition, we do not anticipate that any new carbon-based facilities will 

be built. As a result, manufacturers of carbon-based friction materials will not be regulated under 

% 

the friction materials manufacturing NESHAP. 

Forty-seven facilities manufacture resin-based friction materials. At these facilities, friction 
ingredients are mixed with resins which when cured bind the friction ingredients together. In most 
cases, mixing can be done without the aid of a solvent. However, for some friction materials, 
solvents are needed to enhance mixing and as a process aid in later stages. Of the 47 facilities that 
manufacture resin-based friction materials, only four use solvents to mix friction materials. All 
four are believed to be major sources of HAP due to releases of the solvents used. The HAP- 
containing solvents include n-hexane, toluene, and trichloroethylene. 

Based on our review, we believe that solvent mixing is the only significant HAP emission source 
associated with friction materials manufacturing. Therefore, the friction materials manufacturing 
NESHAP establishes emission limitations for HAP emissions only from solvent mixers at new and 
existing sources that manufacture resin-based friction materials. 

2.1.3 Major Sources 

The number of major sources in the source category is estimated by calculating total HAP 
emissions for each facility at production capacity, considering controls already in place. Of the 
147 friction products manufacturing facilities for which ICR responses were submitted, 4 were 
estimated, to be potential major sources. The emission estimation methodology is presented in 
Appendix B. All four of the major sources are resin-based friction materials manufacturers that 
utilize solvent mixers in the manufacturing process. These four facilities are located in Indiana, 


2-5 


North Carolina, Tennessee, and Wisconsin. The remainder of this chapter will address only the 
resin-based friction materials manufacturing process and the four facilities estimated to be major 
sources. 

There may be some friction materials manufacturing facilities which are not major for processes 
included in the friction materials manufacturing source category, but which may be major for 
surface coating or degreasing operations. These types of operations are subject to other standards 
and are not regulated under the proposed friction materials manufacturing NESHAP. The specific 

types of operations not included in the proposed regulation are discussed in Section 2.1.4 below. 

% 

2.1.4 Source Types Not Regulated 

As described above, assemblers, rebuilders, sintered friction materials manufacturers, carbon- 
based friction materials manufacturers, and resin-based friction materials manufacturers that do not 
use solvents as process aid in mixing friction ingredients will not be included in the proposed 
friction materials manufacturing NESHAP. Additionally, there are other processes that are 
covered under other standards as described below. 

During the manufacture of friction products, a painting process and/or an adhesive application 
process may be included in the process line. The application of paints and adhesives (coatings), 
including drying ovens and equipment cleaning, will be covered under the Miscellaneous Metal 
Parts and Products Surface Coating NESHAP (40 CFR Part 63, Subpart MMMM), or the Plastic 
Parts Surface Coating NESHAP (40 CFR Part 63, Subpart PPPP). As a result, the proposed 
friction materials NESHAP will not regulate any surface coating processes. Many facilities also 
perform metal preparation processes that include degreasing operations. Degreasing equipment 
that uses halogenated solvents will be covered under the Halogenated Solvents Cleaning NESHAP 
(40 CFR Part 63, Subpart T) and, therefore, will not be regulated under the proposed friction 
materials NESHAP. 

In recent years, some friction products manufacturing facilities have changed their product 
formulations to remove some of the more hazardous components, such as lead and asbestos. Based 
on the responses to the ICR, only three facilities reported currently using asbestos in their product 


2-6 


formulations; none of these three facilities are estimated to be major sources. The asbestos 
contents reported range from 43 to 75 percent, with an average of 60 percent. Asbestos emissions 
from the use of asbestos-containing materials are covered under the Asbestos NESHAP (40 CFR 
Part 61, Subpart M) and, therefore, are not included in the proposed friction materials 
manufacturing NESHAP. 

21.5 SIC and NAICS Codes 

Friction materials manufacturing is covered by several Standard Industrial Classification (SIC) 

codes and North American Industry Classification System (NAICS) codes. Friction materials 

% 

manufacturing is typically classified under SIC 3714, Motor Vehicle Parts and Accessories, Brake 
and Brake Systems, Including Assemblies and NAICS 33634, Motor Vehicle Brake System 
Manufacturing. Some facilities manufacture other products in addition to friction materials, and 
may have reported the SIC code for the product which makes up the majority of their annual 
production. A summary of SIC codes reported in the ICR responses for the four major facilities, 
and their respective NAICS codes, is presented in Table 2-2. 

2.1.6 Small Businesses 

Of the four major sources, one was determined to be a small business, based on SIC codes 
reported in the ICRs and on the Small Business Association’s (SBA) small business size 
regulations. The SBA small business cutoffs for the SICs reported by the four major sources are 
presented in Table 2-3. Small business cutoffs for the SICs reported were either 500 or 750 
employees, with most cutoffs being 500 employees. 4 


2-7 


Table 2-2. Distribution of SIC Codes Reported in ICR Responses for Major Sources in the 

Friction Materials Manufacturing Source Category 


SIC code 

SIC definition 

Number of 
facilities" 

| NAICS 
code 

NAICS definition 15 

3292 

Asbestos Products 
(Asbestos Brake Linings 
and Pads) 

1 

33634 

Motor Vehicle Brake System 
Manufacturing (pt) 

* 3299 

Nonmetallic Mineral 
Products, N.E.C. (Other 
Nonmetallic Mineral 
Products) 

1 

327999 

All Other Miscellaneous 
Nonmetallic Mineral Product 
Manufacturing (pt) 

3499 

Fabricated‘Metal 
Products, N.E.C. (Other 
Metal Products) 

• 1 

332999 

All Other Miscellaneous 
Fabricated Metal Product 
Manufacturing (pt) 

3568 

Mechanical Power 
Transmission 

Equipment, N.E.C. 

1 

333613 

Mechanical Power 
Transmission Equipment 
Manufacturing 

3714 

Motor Vehicle Parts and 
Accessories (Brakes 
and Brake Systems, 
Including Assemblies) 

1 

33634 

Motor Vehicle Brake System 
Manufacturing (pt) 

Not 

reported 0 


1 


• • 


d Total is greater than four as some facilities reported two SIC codes. 

b If more than one definition was available for a specific SIC or NAICS Code, the most appropriate definition was 


chosen. 

c Facilities not reporting an SIC code were assigned SIC 3714 for determining small business status. 


Table 2-3. Small Business Association Cutoffs for SIC Codes 

Reported by Major Sources 


SIC code 

Small business size cutoff, no. of employees 

3292 

750 

3299 

500 

3499 

500 

3568 

500 

3714 

750 


2-8 






























2.1.7 Markets 

The resin-based friction materials produced using solvent as a process aid are used by numerous 
market segments, including railroad, automotive, and industrial. Table 2-4 summarizes the 
distribution of market segments for products manufactured by the four major source friction 
materials manufacturing facilities. Table 2-5 lists the product types produced by the four major 
facilities. Table 2-6 summarizes the 1996 production and production capacity data leported in the 
ICR responses for the four major facilities. 


Table 2-4. Distribution of Product Market Segments 

for Major Sources 


Product market 

Number of facilities 3 

Automotive 

/*■> 

z 

Railroad 

1 

Industrial 

1 

Other 

1 


a Total is greater than four because one facility manufactures products for more than one 
market segment. 


Table 2-5. Distribution of Product Type for Major Sources 


Product type 

Number of facilities 3 

Brake lining 

1 

Brake shoe 

1 

Brake pad 

1 

Brake puck 

1 

Friction material 

1 

Industrial friction 

1 


a Total is greater than four because one facility manufactures more than one product type. 


2-9 




























Table 2-6. Reported 1996 Production and Capacity for Major Sources 3 


Range (tpy) 

Number of facilities 

1996 production 

Capacity 

100 to 500 

2 

0 

501 to 1,000 

1 

1 

*'1,001 to 10,000 

0 

2 

10,001 to 20,000 

1 

0 

20,001 to 40,000 

0 

1 


3 Includes production of resin-based products only. 

2.2 RESIN-BASED FRICTION MATERIALS MANUFACTURING 
PROCESS 

Resin-based friction materials are used to make a variety of products. Figures 2-2 and 2-3 present 
simplified process flow diagrams for the manufacture of brake shoes and linings, and disc pads 
and pucks, respectively. These products are manufactured primarily for the automotive industry, 
but are also produced for industrial and railroad applications. 

All four of the major sources reported both their actual annual production and annual production 
capacity in their ICR responses. Total 1996 annual production of resin-based products where 
solvent is used at these four facilities is approximately 13,000 tpy. Total 1996 annual production 
capacity for these products at the four facilities is approximately 39,000 tpy. In general, the 
industry is operating well below its capacity for these products, with an overall production 
utilization of approximately 33 percent. 

The principal operations included in the manufacture of resin-based friction materials can be 
classified into four general areas: (1) raw material preparation; (2) forming; (3) curing; and 
(4) assembling and finishing. These four areas, and the specific equipment types (emission units) 
found in each area, are described in the following sections. 5,6,7 


2-10 
















Finished Product: 
Brake Shoe 


Figure 2-2. Simplified process flow diagram for the manufacture of 

brake shoes and strip lining. 


2-11 





































Finished Product: 
Disc Brake Pad 


Figure 2-3. Simplified process flow diagram for the manufacture of 

disc brake pads and pucks. 


2-12 


































2.2.1 Raw Material Preparation 

The equipment in the raw material preparation area accomplishes the blending of individual 
ingredients (reinforcement material, property modifiers, resins, solvents, and other additives) in 
the proportions necessary to manufacture a friction product with the desired specifications. 

Process units in the raw material preparation area include mixers, granulators, and dryers. 

>r 

Mixing is accomplished in discreet batches. Double-arm mixers are the most common type of 
mixer used. A typical batch includes between 300 and 1,000 pounds (lb) of friction ingredients, 
and takes between 20 minutes and 1 hour* to mix. When solvents are used in the preparation of 
friction materials, the solvents are typically added as a process aid to obtain a homogenous mix of 
material. After mixing, most of the solvent is extracted from the friction material. However, some 
solvent is allowed to remain in the friction mix as a process aid for further process operations. 
Solvent mixers are typically batch mixers operated at slightly elevated temperatures. Typically, 
the reinforcement material, property modifiers, resin (if any), and any other additives are loaded 
into the mixer, and then the solvent is added. Some solvent mixers are completely enclosed, 
having lids that seal. With this type of mixer, the solvent is pumped into the mixer after the other 
ingredients have been added and the lid has been closed and sealed. After mixing, the solvent is 
removed under vacuum and recovered in a solvent recovery system. The recovered solvent may 
be reused in future batches of friction material mix. Other solvent mixers have covers that do not 
seal; with this type of mixer the solvent is not recovered. 

Batches of mixed friction material may then be processed through a granulator to obtain a uniform 
particle size in the friction material. A granulator extrudes the material through a 0.25 to 0.5 inch 
die, and then cuts the extruded material into 0.5 to 1 inch lengths. Uniform particle size is 
important in obtaining the proper distribution of materials and optimum curing characteristics. 

In some cases, friction material is dried after mixing, but before the forming step. Material dryers 
use indirect heat to remove most of the remaining solvent from the mix. Natural gas or 
steam is used to heat the dryer to around 150°F. Fumes from the dryer may be vented through a 
stack to the atmosphere, or may be released inside the manufacturing building as fugitive 
emissions. 


2-13 


2.2.2 Forming 

The blended and prepared friction material is then transferred from the raw material preparation 
area to the forming area, where the material is formed into shapes. Forming equipment includes 
extruders, roll machines, and hot presses. 

Extruders are used to form tapes and pellets of friction material. Pellets are formed by forcing the 
moist friction material through perforations in a metal die and cutting the continuously formed 
strands to a predetermined length. Tapes t are formed by forcing the friction material through a 
metal die with an appropriately-shaped slot in a heated extruder head. 

Roll machines are used to form flat, pliable tapes, similar to those produced by an extruder, and 
are also used to produce wider sheets of friction material. The moist friction material is metered 
between a series of rollers which form a continuous strip of friction material with a preset width 
and thickness. 

/ 

Hot presses are used to foim disc brake pucks, integrally-molded disc brake pads, brake segments, 
and brake blocks. Hot presses apply heat and pressure over time to consolidate the friction mix 
into a solid product. Premeasured quantities of friction mix are poured into each press cavity. As 
heat and pressure are applied, the material is partiaily cured. For some IM pads, the friction 
material is simultaneously attached to the metal backing plate during hot pressing; in this way they 
are formed, partially cured, and assembled in one step. Hot presses may be single- or 
multi-opening. Most hot presses are electrically- or steam-heated. Press temperatures range from 
285° to 450°F, with an average operating temperature of 315°F. Press cycle times range from 0.2 
to 240 minutes, with an average press time of about 20 minutes. Both press temperature and cycle 
time vary, depending on product size and composition. 

2.2.3 Curing 

After the friction shapes are formed, they must be cured. Curing equipment includes curing ovens 
and post bake ovens. Hot presses used to form friction material also begin the curing process; 


2-14 


however, a post bake or curing oven is used to ensure that the friction material is fully cured. 
Where hot presses are not used to form the friction material, uncured friction material from the 
forming process is cured in batch or continuous curing ovens. Oven cycle times vary from 1 to 
46 hours, with an average cycle time of 13 hours. Oven temperatures ramp up and then down over 
the cycle. Oven temperatures range from 180° to 500°F, with an average temperature of 370°F. 
Oven cycle times and temperatures vary with product size and composition. 

2.2.4 Assembling and Finishing 

Once the friction material is formed and cured, it is finished and assembled with some type of 
metal backing. Friction material to be sold to assembly plants or to rebuilders is sold as-is, and is 
not assembled with the metal backing. Finishing operations bring the friction product to final 
specifications. These operations include machining, painting, and edge coding. Assembly 
operations include steel preparation (i.e., degreasing), adhesive application, oven bonding, 
riveting, and attachment of hardware (e.g., mounting brackets, wear sensors, and noise 
suppressors). 

2.3 CHARACTERIZATION OF HAP EMISSIONS FROM RESIN-BASED 
FRICTION MATERIALS MANUFACTURING EMISSION UNITS 

The nature and quantity of HAP emissions from the manufacturing of friction materials is driven 
almost entirely by whether HAP containing solvents are used in mixing. The primary HAP emitted 
from the major source friction materials manufacturing facilities are HAP solvents from mixing 
operations. Currently, these include n-hexane, toluene, and trichloroethylene. The main sources of 
these HAP emissions are the solvent mixers. Other potential sources of HAP solvent emissions 
include granulators, dryers, extruder", roll machines, hot presses, and ovens. 

Baseline emissions are defined as actual HAP emissions from facilities in the absence of 
additional regulation. Baseline emissions are estimated by calculating total HAP emissions for 
each facility at actual production levels, considering controls already in place. The HAP solvent 
emission estimates were developed using a mass balance approach and control technology 
efficiencies. The emissions estimates for resin components (phenol and formaldehyde) are based 


2-15 


on the available emission test data. 3 Table 2-7 presents the potential and baseline organic HAP 
emissions from the four major source friction materials manufacturing facilities. 


Table 2-7. Potential and Baseline Annual HAP Emissions 
from Friction Materials Manufacturing Major Sources 


HAP compound 

Potential emissions, 

tpy 

Baseline emissions, 
tpy 

Phenol 

5.7 

2.0 

Formaldehyde 

1.4 

0.5 

Toluqne 

222.0 

62.5 

Trichloroethylene 

192.1 

18.4 

n-Hexane 

2,644.2 

556.4 

Total HAP 

3,065.5 

639.9 


Emissions from mixers can occur as solvent is added to the mixer, during the mixing cycle, and as 
fugitive emissions when the mixed material is transferred from the mixer to the next process 
operation. The type and quantity of organic HAP emissions from solvent mixers varies depending 
on the type of solvent used, the amount of solvent used per batch, the configuration of the mixer, 
and the presence or absence of a solvent recovery system. The three HAP solvents used at 
solvent-based friction materials manufacturing facilities are n-hexane, toluene, and 
trichloroethylene. Three of the seven solvent mixers are equipped with solvent recovery systems 
designed to minimize HAP emissions and to reclaim solvent for reuse. For these mixers, the 
solvent is removed from the mixed material by vacuum extraction and collected in either a 
condenser (two mixers) or a carbon adsorber (one mixer). The reclaimed solvent is reused in the 
process by the two facilities with condensers, and sold by the facility with the carbon adsorber. 

Residual solvent that is not recovered or is emitted at the solvent mixer can be emitted in 
subsequent processes as the friction material is processed through extruders, roll machines, 
granulators, dryers, hot presses, and ovens. The potential for emissions from these downstream 
processes is proportional to the quantity of residual solvent retained in the friction material after 
mixing. 


2-16 














Small amounts of phenol and formaldehyde (HAP components of phenolic resins) are emitted from 
hot presses and curing ovens. At the four major HAP sources, phenol and formaldehyde emissions 
account for less than 1 percent of the total HAP emitted. None of the existing hot presses or curing 
ovens at the four major sources are equipped with HAP emission controls. Available test data 
indicate that the phenol and formaldehyde emissions are on the order of 5 parts per million (ppm) 
or less, which is below the level which can effectively be controlled by add-on controls. 8 

2.4 EMISSION TEST DATA 

Minimal emission test data were received with the ICR responses. Additional test reports and 
summary emission data were received from States and from follow-up calls to individual 
facilities. Eight complete emission test reports and six partial or summary reports were received. 
These reports include emissions data for mixers, hot presses, and curing ovens. The pollutants 
tested include n-hexane, trichloroethylene, toluene, phenol, formaldehyde, and total hydrocarbons. 
A summary of the available emission test data is presented in a separate memorandum. 8 

2.5 EXISTING STATE REGULATIONS 

As mentioned previously, there are several emission units at friction materials manufacturing 
facilities that are covered under other Federal emission standards; specifically, degreasing 
operations, coating operations, and asbestos operations. Many States have regulations applying to 
these operations. However, because these emission units are not regulated under the proposed 
friction materials manufacturing NESHAP. these State regulations are not summarized in this 
report. The only State regulations that have been found to be applicable to the friction materials 
manufacturing sources covered under this standard are general manufacturing volatile organic 
compound (VOC), particulate matter (PM), and combustion source regulations. 

In addition to general VOC regulations, many States have their own air toxics programs that may 
apply to friction materials manufacturing facilities. These regulations typically regulate a large 
number of chemical compounds. Many States have their own list of air toxics, many of which are 
also designated as organic HAP under the Clean Air Act. These air toxics regulations typically 
specify allowable fenceline concentrations for the individual air toxics. If a facility’s annual 
emissions of a regulated compound exceed a specified level, the State may require a facility to 


2-17 


perform dispersion modeling to determine whether the allowable concentration is exceeded at any 
point beyond the fenceline. The decision to require modeling depends on several factors, 
including the toxicity of the pollutant, its status as a VOC or organic HAP, the attainment status of 
the location, and other considerations. If emissions exceed the allowable concentration, the 
facility must reduce emissions. 

>r 

One facility has a State operating permit with requirements specific to the solvent recovery system 
controlling emissions from the solvent mixer at the facility. For product batches that are mixed 

onsite at the facility, the State operating permit for this facility requires that the facility collect at 

% 

least 85 percent (by weight) of the solvent that is added to those batches, averaged over any week. 
The permit further requires that the facility calculate and record a unique batch identification 
number for each batch mixed, the weight of solvent added to each batch, the weight of solvent 
recovered for each batch, and the weekly average solvent collection efficiency for the recovery 
system. Solvent recovery records from this facility show that a 7-day block average of 85 percent 
solvent recovery has been consistently achieved. 9 

2.6 REFERENCES 

1. Kirk-Othmer Encyclopedia of Chemical Technology. Kroschwitz, J. I. (Ed.). New York, 
John Wiley & Sons. 1985. 

2. U. S. Census Bureau. Motor Vehicle Brake System Manufacturing 1997 Economic Census 
Report. 

3. U. S. Census Bureau. Statistical Abstract of the United States: The National Data Book. 

4. U. S. Small Business Administration. Small Business Size Standards. October 2000. 

5. Memorandum from Midwest Research Institute, to Zapata, S., EPA/ESD. Site Visit 
Report-Plant A. 

6. Memorandum from Midwest Research Institute, to Cavender, K., EPA/ESD. Site Visit 
Report-Plant B. 

7. Memorandum from Midwest Research Institute, to Zapata, S., EPA/ESD. Site Visit 
Report-Plant C. 


2-18 


8. Memorandum from Abraczinskas, M., Bullock, D., Holloway, T., and Turner, M., Midwest 
Research Institute, to Cavender, K., EPA/ESD. August 3, 2001. Summary of Emission Test 
Data. 

9. Air Pollution Control Construction and Operation Permits for Plant A. 


2-19 


-• Chapter 3 

Emission Control Techniques 

This chapter discusses organic HAP emission control techniques that are currently being used in 

\ 

the friction materials manufacturing industry to control emissions from solvent mixers. There are 
two general approaches to reducing organic PIAP emissions resulting from solvent mixers: add-on 
control devices and pollution prevention. 

The first approach to limiting organic HAP emissions from solvent mixers utilizes capture systems 
and add-on control devices io remove the HAP from the air stream. Recovery devices are used to 
collect organic HAP (typically solvents) for reuse in the process; consequently, they are not 
emitted to the atmosphere. Organic HAP in an exhaust gas stream can be collected through 
condensation, or by adsorption of the contaminants onto a porous bed. Both condensers and 
carbon adsorbers are used to recover HAP solvents from solvent mixers. Design, factors affecting 
performance, control efficiency, and monitoring of condensers and carbon adsorbers are described 
in sections 3.1 and 3.2, respectively. 

An alternative approach to limiting organic HAP emissions, focusing on pollution prevention, is 
highly dependent on the specific product being manufactured and its applications. Generally, the 
idea is to substitute currently used materials with low-HAP or HAP-free materials (solvents, 
resins, property modifiers, etc.). Section 3.3 provides a discussion of pollution prevention 
opportunities in the friction materials manufacturing industry. 


3-1 


3.1 CONDENSERS 

Condensers are used to separate one or more volatile components of a vapor mixture from the 
remaining vapors through saturation followed by a phase change. The phase change from gas to 
liquid can be achieved in two ways: (1) by increasing the system pressure at a given temperature, 
. or (2) by lowering the temperature at a constant pressure. 1-3 Because condensers typically reduce 
th* temperature of the gas stream with a coolant, this section addresses the latter method. A 
schematic diagram of a typical condenser is provided in Figure 3-1. 


Coolant 

inlet 


Non continuing 
vapor outlet 


Coolant 

outlet 


channel 


Condensate 

outlet 


Reversing 

channel 



Figure 3-1. Typical shell-and-tube condenser. 3 


Condensers can generally be classified as either surface condensers or contact condensers. 
Surface condensers are usually shell-and-tube heat exchangers. The coolant typically flows 
through the tubes and the vapors condense on the shell outside the tubes. The condensed vapors 
form a film on the cool tubes and drain by gravity to a collection tank for storage or disposal. No 
secondary pollutants are generated from the operation of surface condensers because the coolant 
flows through a closed system. 1-3 Based on the responses to ICRs, the condensers in place at 
friction materials manufacturing facilities are surface condensers. 


3-2 









































Contact condenser designs are similar to spray towers. In contrast to surface condensers where 
the coolant does not contact either the vapors or the condensate, in contact condensers, the vapor 
mixture is cooled by spraying a cool liquid directly into the gas stream. 1-3 

Condensation occurs when the partial pressure of the condensible pollutant in the waste gas stream 
is equal to its vapor pressure as a pure substance at the operating temperature of the condenser. 

The waste gas stream is cooled by transfer-of its heat to a refrigerant or coolant; the waste gas 
becomes saturated with one or more of its pollutants at the dew point or saturation temperature, 

and as the gas continues .to cool, the pollutants condense. The dew point temperature can be 

% 

predicted from the temperature-vapor pressure curve for the pollutant and its mole fraction in the 
waste gas stream. The temperature required to achieve a given removal efficiency or outlet 
concentration depends on the outlet vapor pressure of the pollutant at vapor-liquid equilibrium. 
When the partial pressure is known, the condensation temperature can be determined (using 
temperature-vapor pressure relationship, such as Antoine’s equation). 1,3 

3.1.1 Factors Affecting Performance 

The design and operation of a condenser are affected significantly by the number and nature of the 
components present in the emission stream. For example, condenser efficiency is sensitive to the 
inlet HAP concentration. In most HAP control applications, the emission stream will contain large 
quantities of noncondensible and small quantities of condensible compounds. To separate the 
condensible component from the gas stream at a fixed pressure, the temperature of the gas stream 
must be reduced. The more volatile a compound (i.e., the lower the normal boiling point), the 
larger the amount that can remain as vapor at a given temperature; hence the lower the temperature 
required for saturation (condensation). 2 

The coolant used in a condenser depends upon the saturation temperature needed to condense the 
pollutants of interest in the gas stream. Chilled water can be used for condensation temperatures 
that are below 7°C (45°F), brines for below -34°C (-29°F), and chlorofluorocarbons for 
condensation temperatures below -34°C (-29°F). Temperatures as low as -62°C (-80°F) may 
be necessary to condense some streams. When such low temperatures must be achieved to reach 


3-3 


the dew point for a particular pollutant, other components of the waste gas stream, such as water, 
can solidify and foul the heat transfer surface. 1,3 

Table 3-1 summarizes the condenser operating parameters provided in the ICR responses. 


Table 3-1. Condenser Operating Parameters Reported in ICR Responses 


[-*- 

Condenser type 

Coolant 

Inlet gas temperature, 
°C(°F) 

Outlet gas temperature, 

°C (°F) 

Non Contact 

freon 

40 (100) 

10 (50) 

Non Contact 

water 

65 (150) 

15 (60) 

Vertical 

water 

90 (190) 

25 (80) 

n/a 

refrigerant 

n/a 

n/a 

Shell and Tube 

water 

90 (190) 

50 (120) 

Shell and Tube 

water 

n/a 

65 (150) 

Shell and Tube 

water 

n/a 

65 (150) 

Surface (Indirect) 

glycol 

90 (190) 

15 (60) 


n/a = not available 


3.1.2 Control Efficiency 

Condensers generally achieve removal efficiencies ranging from 50 to 95 percent. The removal 
efficiency of condenser systems designed to control exhaust streams containing air/organic HAP 
mixtures depends primarily on the following parameters: 

• Inlet and outlet waste gas temperature; 

• Volumetric flow' rate of the w'aste gas stream; 

• Inlet and outlet coolant temperature; 

• Concentrations of the organic HAP in the exhaust stream; 

* 

• Absolute pressure of the vent stream; and 

• Properties of the organic HAP in the vent stream (dew' points, heats of condensation, 
heat capacities, and vapor pressures). 1,3 


3-4 




















The performance of two existing condensers installed as solvent recovery devices on solvent 
mixers at friction materials manufacturing facilities was evaluated. For the first condenser, only 
anecdotal information on recovery efficiency was available. However, reliable data documenting 
recovery efficiency is available for the second condenser. Solvent recovery records from this 
facility show that a 7-day block average of 85 percent solvent recovery has been consistently 
achieved. 

3.13 Current Monitoring Practices 

The primary indicators of the performance of condensers are the condenser outlet VOC 

% 

concentration, condenser outlet temperature, and coolant inlet temperature. Other parameters that 
indicate condenser performance include coolant outlet temperature, exhaust gas flow rate, pressure 
drop across condenser, coolant flow rate, pressure drop across coolant recirculation system, and 
condensate collection rate. Table 3-2 lists these indicators and briefly describes the relationship 
of the indicator to condenser performance. A summary’ of ICR responses indicating the existing 
monitoring procedures for condensers at friction materials manufacturing facilities is presented in 
Table 3-3. Generally, the existing parameters monitored include outlet gas temperature, outlet 
coolant temperatuie, and system pressure drop. 


Table 3-2. Summary of Performance Indicators for Condensers 


Parameters 

Performance indication 

Comments 

Primary indicators of performance 

Outlet VOC concentration 

Direct measure of outlet 
concentration. 

Best indicator of condenser performance; can be 
monitored continuously or periodically. 

Outlet temperature 

Indicates if gas is being cooled 
to/below dewpoint of target 
compounds; indicator of level of 
condensation. 

Too high indicates condensation to the level expected wil 
not occur; decrease in outlet temperature may indicate 
plugging or fouling problems. 

Coolant inlet temperature 

Indicates if condenser is operating 
as designed. 

If inlet gas temperature and flow rate do not vary, is 
comparable to outlet gas temperature as indicator of 
condenser performance; increase in coolant inlet 
temperature indicates lower organic compound removal 
rate. 


3-5 













Table 3-2. (continued) 


Parameters 

Performance indication 

Comments 

Other performance indicators 

Coolant outlet temperature 

If coolant inlet temperature and are 
flow rates also are measured, 
indicates level of heat transfer from 
inlet exhaust stream. 

By itself, would be less reliable indicator of performance 
than other parameters listed above; increase would 
indicate decrease in organic compound removal rate. 

Exhaust gas flow rate 

.Determines residence time within 
condenser. * 

Increase in flow rate could indicate a decrease in 
condenser performance. 

Pressure drop across 
condenser 

Indicator of plugging or fouling 
within condenser. 

Increase in pressure drop indicates obstruction in 
condenser and likely decrease in condenser performance; 
fouling decreases heat transfer rate.' 

Coolant flow rate 

Affects heat transfer rate. 

Decrease indicates decrease in condenser performance; 
parameter is of limited use without coolant temperature 
data. 

Pressure drop across 
coolant recirculation system 

Indicates plugging and/or fouling of 
condenser coolant tubes. 

Comparable to monitoring coolant flow rate (see above). 

Condensate collection rate 

Organic compound removal rate. 

Useful indicator of condenser performance only if proces: 
gas stream characteristics do not vary. 

Periodic inspection 

Fouling of tubes, corrosion. 

Fouling decreases heat transfer. 


Table 3-3. Condenser Monitoring Procedures Reported in ICR Responses 


Parameters 

monitored 

Monitoring 

frequency 

Type of device used 

Recordkeeping 

procedures 

Operation and maintenance 

Equipment 

Control device 

Different 

pressures 

Daily 

Pressure gauge 

Recorded manually 

As needed 

Visual inspection of 
structure, daily 

Temperature 

Daily 

Built in gauge 

Recorded manually 

As needed 

Visual inspection of 
cooling and filter 
chamber, weekly 

Vacuum pressure 

Continuous 

Pressure gauge 

Manually recorded 
per batch 

Check per batch 

Visual inspection 

Temperature 

Continuous 

Temperature gauge 

Manually recorded 
per batch 

Check per batch 

Visual inspection 

Water & gas outlet 
temperature 

Daily 

Dial thermometers 

Maintain log of 
water temperature 


Clean condensers as 
required 


3.2 CARBON ADSORBERS 


3-6 










































Carbon adsorbers are used for both air pollution control and solvent recovery. The carbon 
adsorption process used to control organic HAP and VOC emissions from waste gas streams can 
be subdivided into two sequential processes. The first process involves the adsorption cycle, in 
which the waste gas stream is passed through the adsorbent bed for contaminant removal. The 
second process involves regeneration of the adsorbent bed, in which contaminants are removed 
using a small volume of steam or hot air and recovered using condensation, so that the adsorbent 
(carbon) can be reused for contaminant removal. 

Adsorption is the capture and retention of a contaminant (adsorbate) from the gas phase by an 

% 

adsorbing solid (adsorbent). The four types of adsorbents most typically used are activated 
carbon, aluminum oxides, silica gels, and molecular sieves. Activated carbon is the most widely 
used adsorbent for air pollution control and is the only type of adsorbent discussed in this section. 4 

The two main mechanisms of adsorption are physical adsorption and chemisorption. Physical 
adsorption (otherwise known as van der Waals adsorption) uses a weak bonding of the adsorbate 
molecules to the adsorbent. The van der Waals forces within the bond are similar to the forces 
that attract molecules in a liquid and are easily overcome by the application of heat or the 
reduction of pressure. Chemisorption uses chemical bonding by inducing a reaction between the 
adsorbate and the adsorbent. 5 

There are three basic types of adsorption systems, which can be categorized by the manner in 
which the adsorbent bed is maintained or handled during the adsorption and regeneration cycles. 
These three types of systems are: (1) fixed or stationary bed, (2) moving bed, and (3) fluidized 
bed. The stationary bed design is the most common and is the only design described in this 
section. 

A stationary-bed, regenerable carbon adsorption system is depicted in Figure 3-2. The 
components of the carbon adsorption system include a fan (to convey the waste gas into the carbon 
beds); at least two stationary-bed carbon adsorption beds; a stack for the treated waste gas outlet; 
a steam valve for introducing desorbing steam; a condenser for the steam/contaminant desorbed 
stream; and a decanter for separating the organic HAP condensate and water. 


3-7 


Exhaust air 



Figure 3-2. Typical stationary-bed, regenerate carbon adsorption system. 1 


In a typical dual stationary-bed system, the vapor is collected from various sources, transported 
through a particulate filter and into one of two carbon adsorption beds. As the carbon adsorber 
operates, three zones form within the bed: the saturated zone, mass transfer zone, and fresh zone. 
In the saturated zone, which is located at the entrance to the bed, the carbon has already adsorbed 
its working capacity of VOC; no additional mass transfer can occur in this zone. The mass transfer 
zone is where VOC is removed from the gas stream. The carbon in this zone is at various degrees 
of saturation, but is still capable of adsorbing VOC. The fresh zone is the region of the bed that 
has not encountered VOC-laden air since the last regeneration. This zone has a full working 
capacity available for adsorption of additional VOC. 

As the carbon bed operates, the mass transfer zone moves through the bed in the direction of flow 
toward the bed outlet. Breakthrough occurs when the mass transfer zone first reaches the bed 


3-8 





























outlet. At this point, a sharp increase in the outlet VOC concentration occurs. The available 
adsorption time (the time before breakthrough occurs) depends on the ariiount of carbon in the bed, 
the working capacity of the bed, and the VOC concentration and mass flow rate of the gas stream. 
Once the breakthrough point is reached, the carbon bed must be regenerated. When this occurs, the 
flow of VOC-laden air is redirected to the second bed, while the first bed undergoes a 
regeneration cycle. 

Regeneration is the process of desorbing (that is, reversing the adsorption process and separating 
the contaminants from the carbon), and is accomplished by increasing the temperature and/or 
reducing the system pressure. The most common method of regeneration is steam stripping. Low- 
pressure, superheated steam is introduced into the carbon bed. The steam desorbs and carries the 
VOC through a condenser, then through a decanter and/or distillation column for separation of the 
VOC from the steam condensate. 

Another regeneration method is the use of hot, inert gas or hot air. With either steam or hot air 
regeneration, the desorbing agent flows through the bed in the direction opposite to the waste 
stream, allowing the exit end of the carbon to remain contaminant-free. The regenerated carbon 
bed is then ready to be put back on-line when the second bed reaches breakthrough. 13 4 

3.2.1 Factors Affecting Performance 

Several factors affect the amount of material that can be adsorbed onto the carbon bed. These 
factors include type and concentration of contaminants in the waste gas, system temperature, 
system pressure, humidity of waste gas, and residence time. 6 

The type and concentration of contaminants in the waste stream are major factors in the adsorption 
capacity of the carbon. In general, adsorption capacity increases with a compound’s molecular 
weight or boiling point, provided all other parameters remain constant. There is also a 
relationship between concentration and the carbon adsorption capacity. As concentration 
decreases, so does the carbon capacity. However, the capacity does not decrease proportionately 
with the concentration decrease. 6 


3-9 


Increases in operating temperature decrease adsorption efficiency. At higher temperatures, the 
vapor pressures of the contaminants increase, reversing the mass transfer gradient. Contaminants 
would then be more likely to return to the gas phase than to stay on the carbon. At lower 
temperatures, the vapor pressures are lower, so the carbon will likely retain the contaminants. 7 

Iqpreases in the system pressure improve the effectiveness of adsorption. Increases in the gas 
phase pressure promote more effective and rapid mass transfer of the contaminants from the gas 
phase to the carbon. Therefore, the probability that the contaminants will be captured is 
increased. 4 

% 

Although water vapor is not preferentially adsorbed over the contaminants, increases in the 
relative humidity or moisture content of the gas phase generally reduce adsorption efficiency. 
However, the effect of humidity in the gas phase is insignificant for VOC concentrations greater 
than 1,000 parts per million (ppm) and during the initial startup of the adsorption cycle (when the 
carbon is drier). In some instances moisture content in the gas phase can be beneficial. For 
instance, when high concentrations of contaminants with high heats of adsorption are present, the 
temperature of the carbon bed may rise considerably during adsorption due to the exothermic 
nature of the process. The presence of water may minimize the temperature rise. 6 

Adsorption efficiency may also be reduced if contaminants do not have enough contact (residence) 
time with the active sites of the carbon to allow mass transfer to occur. Contaminants especially 
need this time if many molecules (high-concentration streams) are competing for the same sites. 
Residence time of the contaminants with the active sites can be increased by using larger carbon 
beds, but then the pressure drop across the system increases, resulting in increased operating 
cos^. 4 


3.2.2 Control Efficiency 

Carbon adsorption recovery efficiencies of 95 percent and greater have been demonstrated to be 
achievable in well-designed and maintained units. 2 The performance of the carbon adsorption unit 
is negatively affected by elevated temperature, low pressure, and high humidity, as previously 


3-10 


discussed. One carbon adsorber is in use on a solvent mixer and halogenated solvent degreaser at 
a major friction materials manufacturing facility. The adsorber system has demonstrated a VOC 
capture efficiency of 94 percent and a VOC removal efficiency of 99.8 percent, which yields a 
VOC control efficiency of 93.8 percent for the solvent mixing and degreasing operations. 8 
However, this system was not operating under representative conditions during the test, and these 
non-representative data were not sufficiently reliable to use in establishing the level of the 
standard. Additionally, the overall control efficiency does not equate to solvent recovery because 
it does not account for the residual solvent remaining in the mixed material. 

3.2.3 Current Monitoring Practices 

The primary indicators of the performance of carbon adsorbers are the adsorber outlet VOC 
concentration, regeneration cycle timing, and integrated steam flow. Other indicators of adsorber 
performance include bed operating temperature, inlet gas temperature, gas flow rate, inlet VOC 
concentration, pressure drop, and inlet gas moisture content. Table 3-4 lists these indicators and 
briefly describes the relationship of the indicator to adsorber performance. The only monitoring 
practice reported in the ICR responses was taking semi-annual samples of the carbon for bed 
breakthrough and carbon quality. 


Table 3-4. Summary of Performance Indicators for Carbon Adsorbers 


Parameters 

Performance indication 

Comments 

Primary indicators of performance 

Outlet VOC 
concentration 

Direct measure of outlet 
concentration. 

Best indicator of adsorber performance: can be 
monitored continuously or periodically. 

Regeneration 
cycle timing 

Key factor in determining adsorptive 
capacity of bed. 

If regeneration cycles are too infrequent, VOC 
emissions may be excessive; if regeneration 
times are too short, the adsorption capacity of the 
bed is reduced. 

Integrated steam 
flow 

Determines extent to which bed is 
desorbed (regenerated). 

Decreases in steam flow result in a shorter time 
period to reach breakthrough. 

Other performance indicators 

Bed operating 
temperatuie 

Affects adsorptive capacity of bed. 

Adsorptive capacity decreases with increasing 
temperature. 


3-11 


















Table 3-4. (continued) 


Parameters 

Performance indication 

Comments 

Inlet gas 
lemperature 

Indicator of bed operating 
temperature (see above). 

Not as useful as bed operating temperature as an 
indicator of performance, but is an alternative to 
monitoring bed operating temperature. 

Gas flow rate 

Adsoiption capacity of bed. 

Increases in flow rate resuit in a shorter time 
period to reach breakthrough. 

Inlet VOC 
concentration 

System is operating within design 
limits. 

Increases in VOC concentrations may require 
adjustments to regeneration cycle timing. 

Pressure drop 
across adsorber 

Indicator of fouling or channeling 
within bed. 

Increase in pressure drop can indicate fouling of 
bed; decrease in pressure drop can indicate 
channeling. 

Inlet gas moisture 
content 

Adsorptive capacity of bed. 

High moisture content can result in reduced 
adsorptive capacity of bed; applies to inlet VOC 
concentrations less than -1,000 ppm. 


3.3 POLLUTION PREVENTION TECHNIQUES 

Pollution prevention alternatives for reducing air emissions associated with friction materials 
manufacturing can vary widely. The pollution prevention practices involving friction material 
formulations are influenced by the specific product being manufactured, and the product 
performance requirements that must be met. Therefore, specific pollution prevention techniques 
will vary with different products and applications. 


Generally, replacing HAP-containing organic process solvents and resins with non-HAP materials 
has been demonstrated in several products and applications. A specific reformulation technique 
that may have been employed at one facility to reduce air emissions, however, may not work for 
another facility. Techniques involving the reuse of scrap materials, reject products, and baghouse 
catches have also been demonstrated as pollution prevention practices. 


3.4 REFERENCES 


3-12 
















1. Air Pollution Engineering Manual. Buonicore, A. J. and Davis, W. T. (Eds.). New York, 
Van Nostrand Reinhold Company. 1992. 

2. U. S. Environmental Protection Agency. Handbook: Control Technologies for Hazardous 
Air Pollutants. EPA 625/6-91/014. Cincinnati, OH. July 1991. 

3. U. S. Environmental Protection Agency. APTI Course 415, Control of Gaseous Emissions, 
Student Manual. EPA 450/2-81-005. Research Triangle Park, NC. December 1981. 

4. Bethea, R. M. Air Pollution Control Technology. New York, Van Nostrand Reinhold 
Company. 1978. 

5. Cooper, C. D. and Alley, F. C. Air Pollution Control: A Design Approach. Prospect 
Heights, IL, Waveland Press, Inc.» 1994. 

6. Calgon Corporation. Introduction to Vapor Phase Adsorption Using Granular Activated 
Carbon. 

7. Prudent Practices for Disposal of Chemicals from Laboratories. Washington, D.C., 
National Academy Press. 1983. 

8. Emission Test Report for Plant C. 


3-13 


Chapter 4 

MACT Floor and Regulatory Options 




This chapter describes the CAA requirements for MACT standards, the methodology and 
conclusions of the MACT floor analyses for the friction materials manufacturing source category, 
regulatory options considered, and monitoring options identified for the emission units and HAP to 
be regulated. 

4.1 CLEAN AIR ACT REQUIREMENTS 

The amended CAA contains requirements for the development of NESHAP for sources of HAP 
emissions. The statute requires the standards to reflect the maximum degree of reduction in 
emissions of HAP that is achievable for new and existing sources. This control level is referred to 
as MACT. The amended CAA also provides guidance on determining the least stringent level of 
control allowed for a MACT standard; this level is termed the “MACT floor.” 

The approach to selecting the MACT floor depends on the number of major and synthetic area 
sources in each source category. Section 112 (d)(3) of the CAA specifies that NESHAP for 
existing sources are to be no less stringent (but may be more stringent) than, . . the average 
emission limitation achieved by the best-performing 12 percent of the existing sources (for which 
the Administrator has emissions information). . . .” We have interpreted the “average” emission 
limitation as the median of the best-performing 12 percent, or the 94th percentile. In categories or 
subcategories with fewer than 30 major and synthetic area sources, the MACT floor is to be based 
on the average emission limitation achieved by the best-performing five sources. We have 
interpretea the “average” emission limitation as either the mean or median emission limitation of 


4-1 


those best-performing five sources. The MACT floor for new sources corresponds to the level of 
emission control that is achieved ir. practice by the best controlled similar source. 

4.2 MACT DETERMINATIONS 

For NESHAP developed to date, we have used several different approaches to determine the 

floor and beyond-the-floor options for individual source categories depending on the type, 
quality, and applicability of available data.' These approaches are based on: (1) emissions test 
data that characterize actual HAP emissions from presently controlled sources included in the 

source category; (2) existing federally-enforceable emission limitations specified in air 

% 

regulations and facility air permits applicable to the individual sources composing the source 
category; and (3) application of a specific type of control technology for air emissions currently 
being used by sources in the source category or by sources with similar pollutant stream 
characteristics. The available emission test data and the existing State regulations and permit data 
are inadequate for establishing the MACT floor for the friction materials manufacturing industry; 
therefore, the MACT floor will be technology-based. 

4.2.1 Performance of Solvent Recovery Systems on Solvent Mixers 

As reported previously, we surveyed the entire friction materials manufacturing industry and 
determined that four facilities with solvent mixers emit HAP in excess of the major source levels. 
Combined, these four facilities (Plants A, B, C, and D) operate a total of seven solvent mixers, of 
which three are equipped with air pollution controls (solvent recovery systems), and four have no 
control. Table 4-1 lists the control technologies in place on the various emission sources at the 
four major source facilities in the friction materials manufacturing industry. The following 
paragraphs briefly describe the solvent mixers in place at each of the four facilities and the 
performance of the solvent recovery systems. 


4-2 


Table 4-1. Existing Control Technologies for Potential Sources of Organic HAP Emissions 
at the Four Major Source Facilities in the Friction Materials Manufacturing Industry 


Emission unit 

Total number 

No control 3 

Carbon adsorber 

Condenser 

No. 

% 

No. 

% 

No. 

% 

Extruder 

6 

6 

100 





Granulator 

3 

3 

100 





ftot press 

104 

104 

100 





Material dryer 

16 

16 

100 





Mixer (solvent) 

7 

4 

57 

1 

14 

2 

29 

Oven 

42 1 

42 

100 





Roll machine 

4 

4 

100 






a Includes emission units with fabric filters; fabric filters are expected to provide no control for organic HAP 


emissions. 

Plant A has one solvent mixer that uses toluene as the solvent. 1 According to information on air 
releases reported by the facility to the 1997 Toxics Release Inventory (TRI), air emissions of 
toluene are on the order of 45 tpy. 2 After mixing, solvent is drawn out of the mixer under a strong 
vacuum. 1 Data collected by facility personnel indicate that typically more than 95 percent of the 
solvent is removed from the mixed material, with less than 5 percent remaining in the mix. 1 The 
evacuated solvent vapors are then condensed in a non-contact, glycol-chilled condenser which 
cools the vapors to 32°F. ] Liquid condensate is collected and recycled to the process, and 
uncondensed vapor is exhausted to the atmosphere through a stack. 1 

Plant A has a State operating permit which requires that the facility collect at least 85 percent (by 
weight) of the solvent that is added to the mixer, averaged over a calender week. 1 The percent 
solvent recovery is determined for each individual mix batch by weighing the amount of solvent 
loaded into the mixer, and weighing the amount of solvent recovered by the condenser. 1 Plant A 
began collecting solvent recovery data for each batch in January 1999. We reviewed the solvent 
recovery- records from January 1999 through October 1999 and found that the 85 percent solvent 
recovery limit has been consistently achieved on a weekly, or 7-day block average, basis. 3 


4-3 



























Plant B has four solvent mixers that use n-hexane as the solvent. 4 Again,’based on self-reported 
emissions data to TRI for 1998, Plant B emits approximately 450 tpy of n-hexane. 5 Three of the 

four mixers have no air pollution controls. 4 All of the solvent added to these mixers is emitted to 

> 

the atmosphere. The fourth mixer has a solvent recovery system similar to the one described for 
Plant A. 4 Solvent is drawn out of the mixed material by vacuum. 4,6 The solvent vapors are then 
collected by a non-contact, Freon-cooled condenser, which cools the solvent vapor to 60 °F. 4 Once 

V 

per quarter, Plant B performs a solvent mass balance for one batch to evaluate the performance of 
the solvent recovery system. 7 The amount of solvent added to the mixer is measured using a 
calibrated flow meter, and the amount of solvent recovered by the condenser is weighed. 8 The 
results of these measurements indicate that approximately 70 percent of the solvent is recovered by 
the solvent recovery system on average. 4 Using these data and the overall system efficiency, 
facility personnel have determined that approximately 90 percent of the solvent is removed from 
the mix by the solvent recovery system, and that the condenser removes approximately 80 percent 
of the solvent vapors. 4 

Plant C has one solvent mixer that uses trichloroethylene as the solvent. 9 Based on the self- 
reported emissions data to TRI for 1998, Plant C emits approximately 30 tpy of 
trichloroethylene. 10 As with the other two controlled mixers, solvent is removed from the mixer 
under vacuum. 9 No data are available on how much of the solvent is removed from the mixed 
friction material by the vacuum system. The solvent vapors are combined with the emissions from 
a solvent degreaser, and the commingled vapors are collected in a carbon adsorber. 9 The 
adsorbed solvent is recovered weekly by steam stripping the adsorber bed, and the recovered 
solvent is sold. Performance data based on a single inlet/outlet emissions test conducted in 1996 
indicate that the subject adsorber is capable of achieving 94 percent control. 11 It should be noted 
that control efficiency does not equate to solvent recovery because it does not account for the 
residual solvent content remaining in the mixed material. If one assumes that the residual solvent 
content is similar to that achieved at Plant A and Plant B (i.e., between 5 and 10 percent), then the 
corresponding percent of solvent recovered would be on the order of 85 to 90 percent. 


4-4 


Plant D has one solvent mixer that uses toluene as the solvent. 12 Based on the self-reported 
emissions data to TRI for 1998, Plant D emits about 40 tpy of toluene. 13 Plant D has no air 
pollution controls on its mixer, and 100 percent of the solvent used is emitted to the atmosphere. 12 

4.2.2 Selection of MACT 

We have determined that the MACT floor for existing mixers is a solvent recovery system with a 
70 percent solvent recovery efficiency, and the MACT floor for new mixers is a solvent recovery 
system with a 85 percent solvent recovery efficiency. We have also determined that it is both 
technically and economically feasible for*existing mixers to achieve better than the MACT floor 
level of control. Therefore, we are establishing MACT for both new and existing solvent mixers 
at 85 percent solvent recovery efficiency. Table 4-2 summarizes the MACT floor and MACT 
determinations for the sources at the four major source facilities in the friction materials 
manufacturing industry. The following paragraphs describe how we determined the MACT floors, 
and our rationale for going beyond the MACT floor for existing mixers. 


Table 4-2. Summary of MACT Determinations 


Emission unit 

MACT floor 
control technology 

MACT floor for 
existing sources 

MACT for 
existing sources 

MACT floor for 

new sources 

Extruder 

No control 

No control 

No control 

No control 

Granulator 

No control 

No control 

No control 

No control 

Hot press 

No control 

No control 

No control 

No control 

Material dryer 

No control 

No control 

No control 

No control 

Mixer (solvent) 

Solvent recovery 

70% control 

85% control 

85% control 

Oven 

No control 

No control 

No control 

No control 

Roll machine 

No control 

No control 

No control 

No control 


Because there are only seven solvent mixers (fewer than 30 sources), the MACT floor for existing 
solvent mixers is based on the best-performing five sources. The available information does not 
allow for a floor calculation based on actual emissions data or State limits. However, ranking the 
sources by the estimated performance of the control technology applied allows for a floor 
determination based on the median of the best-performing five sources, i.e., the third best¬ 
performing source. 


4-5 


















Each of the three mixers with control is equipped with a solvent recovery system comprised of 
two components: • a vacuum system to remove the solvent from the mixed material, and a control 
device that recovers the solvent from the exhaust. The overall performance of these systems is 
determined by the performances of the individual components, i.e., the efficiency of the vacuum 
system at removing solvent from the mixed material, and the efficiency of the control device in 
removing the solvent vapors from the vacuum exhaust. 


Both Plant A and Plant B use a condenser to recover the solvent vapors. Based on the available 

data. Plant A’s recovery system performs better than the recovery system used at Plant B. Plant 

% 

A’s vacuum system removes 95 percent of the toluene from the mixer, and the condenser removes 
90 percent of the solvent vapor, resulting in an overall solvent recovery efficiency of 85 percent. 
Plant B’s vacuum system is estimated to remove 90 percent of the n-hexane from the mixer, and the 
condenser removes 80 percent of the n-hexane vapors from the.vacuum exhaust, resulting in an 
overall solvent recovery efficiency of 70 percent. 

Plant C uses a cafbon adsorber to recover the trichloroethylene solvent vapors contained in the 
vacuum exhaust coming from the mixer. The 94 percent control efficiency estimated for the carbon 
adsorber is the highest of the three control devices applied. However, as stated previously, we 
have no information from which to assess the effectiveness of the vacuum system at removing the 
solvent from the mixed material. Without this information, we cannot determine the overall 
solvent recovery efficiency achieved by the vacuum systems and carbon adsorbers together. 
Therefore, for the purpose of determining the MACT floor, we have assumed that the recovery 
system at Plant C is comparable to that of the system at Plant A, and we have assigned it an 
85 percent solvent recovery efficiency. 

Given the above, the ranking of the five best sources for purposes of the floor determination is as 
follows: 85 percent for Plant A and Plant C, 70 percent for Plant B, and 0 percent recovery for 
any two of the remaining mixers. The third best-performing source and, thus, the MACT floor for 
existing solvent mixers is the mixer at Plant B with 70 percent solvent recovery. The MACT floor 
for new mixers is based on the best-performing solvent recovery system. We have determined that 


4-6 


Plant A has the best-performing solvent recovery system, and we have set the MACT floor for new 
mixers at an 85 percent solvent recovery efficiency. 

Next, we evaluated options that would be more stringent than the floor. Clearly, requiring existing 
mixers to meet an 85 percent solvent recovery efficiency is an option for existing mixers. To 
evaluate technical feasibility of this option, we examined whether a better-designed and operated 
solvent recovery system could achieve an 85 percent solvent recovery efficiency on Plant B’s 
solvent mixing operation. Plant B was selected because it had the lowest performing solvent 

recovery system of the three controlled mixers. We looked at the volatility of the three different 

% 

solvents used at the existing solvent mixers to determine if the volatility of the solvents could limit 
the vacuum system efficiency, such that, for certain solvents, an 85 percent solvent recovery 
efficiency could not be achieved. Vacuum systems remove solvent from the mixed material by 
evaporation at low pressure. Consequently, the higher the volatility of the solvent, the more easily 
it can be removed by a vacuum system. Of the three solvents used, n-hexane is the most volatile, 
while toluene is the least volatile. Based on the available data, Plant A’s vacuum system 
efficiency of 95 percent is the best of the existing systems. Because Plant A also uses the least 
volatile solvent, it is clear that a vacuum system efficiency of 95 percent can be achieved for all 
three of the solvents used at the existing facilities. 


We then evaluated the condenser used at Plant B, the poorer performer of the sources with 
condensers, to determine if improvements to condenser efficiency are possible. The key parameter 
that determines condenser performance for a given solvent is the outlet temperature of the 
condenser. The lower the outlet temperature of the condenser, the more solvent will be 
condensed, and the higher the condenser efficiency will be. For Plant B, the condenser outlet 
temperature is 60 C F. This compares to an outlet temperature of 32 C F at Plant A. Condenser outlet 
temperatures of 32 °F can be obtained with either a glycol-cooled condenser, or a Freon-cooled 
condenser. The vapor pressure of n-hexane, the solvent used at Plant B, is estimated to be 
approximately 100 millimeters of mercury (mm Hg) at 60°F. At 32°F, the vapor pressure of n- 
hexane is estimated to be approximately 50 mm Hg. This indicates that the penetration (the amount 
of solvent that is not condensed) would be halved by lowering the condenser outlet temperature at 
Plant B from 60°F to 32°F. Because the current condenser is estimated to be 80 percent efficient, 


4-7 


we would predict that a condenser with a 32°F outlet temperature would achieve 90 percent 
efficiency on this gas stream. If Plant B were to install both an improved vacuum system and an 
improved condenser, we predict the overall solvent recovery would be 85 percent (0.95 x 0.90 x 
100 percent = 85 percent). Based on the above analysis, we believe that it is technically feasible 
to achieve 85 percent solvent recovery on each of the existing solvent mixers used at friction 
manufacturing facilities. 

We also believe that it is economically feasible to achieve 85 percent solvent recovery on each of 

the existing solvent mixers. The incremental costs to install and operate a solvent recovery system 

% 

that achieves 85 percent over that of a system that would achieve 70 percent are minimal. 
Furthermore, because the recovered solvent can be reused in the process, the costs of solvent 
purchases will be greatly reduced, which we believe would more than offset the costs of installing 
and operating the solvent recovery system. 

We also evaluated and rejected an option that would prohibit the use of HAP solvents altogether. 

The HAP solvent usage has declined significantly as friction material manufacturers develop 
formulations and processes that either use non-HAP solvents or need no solvents in the mixing 
process (i.e., dry mixing). Personnel at Plant B and Plant C are actively working to identify 
alternatives to the HAP solvents they currently use. Plant B uses a dry mixer to mix many of the 
formulations it currently makes, but they must use n-hexane to mix those formulations w'here the dry 
mixing process cannot meet the performance characteristics needed. They have also investigated 
several non-HAP solvents, but they have not yet identified an acceptable alternative to n-hexane. 
Plant C uses non-HAP solvents to mix many of the friction materials they manufacture, but still 
have a number of formulations that require the use of trichloroethylene to achieve the necessary 
characteristics. While it may be possible in the future to eliminate the use of HAP solvents from 
all friction materials manufacturing, we believe it is not currently feasible to eliminate HAP 
solvents from all friction materials manufacturing. 

4.2.3 Selection of the Standard 

The CAA requires us to set numerical emission limitations if feasible, and it prohibits use of 
operational standards, unless we can demonstrate that the setting and enforcement of an emission 


4-8 


limitation is infeasible. Consequently, we have selected a format for the standard that expresses 
the goal of 85 percent solvent recovery as an emission limit based on the amount of solvent loaded 
into the mixer and the amount recovered. Specifically, the proposed standard would limit the HAP 
solvent emissions to the atmosphere to no more than 15 percent of that loaded into the solvent 
mixer. 

>r 

We also evaluated several averaging times to determine an appropriate averaging time for the 
standard. We determined that long averaging times (such as a 30-day or annual average) v/ould 

not be appropriate because they would allow for long periods of under-performance by the solvent 

% 

recovery system. In addition, one deviation from a 30-day or annual average would put the facility 
at risk of being determined to be out of compliance for the entire period. We determined that 
requiring compliance on a per-batch basis (i.e. no averaging) would also be inappropriate because 
it would not accommodate normal variability in the residual solvent requirements for different 
product mixes. The use of a 7-day block average provides time to detect and correct problems 
(e.g., individual mix batches not achieving the emission limitation) without the risk of the longer 
averaging periods. A 7-day block average is also consistent with the existing State operating 
permit requirements for Plant A. 

4.3 MONITORING OPTIONS 

The applicable monitoring approach for any operation or facility depends on the control 
technology used to meet the applicable emission limit. For processes with control devices, often 
called add-on control devices, monitoring approaches will include continuous emission 
monitoring systems and operating parameter monitoring devices, used in combination w'ith regular 
maintenance and corrective action as indicated. For other processes, improved recordkeeping and 
repcning of pollution control activities may be sufficient. 

« 

The general approach to selecting monitoring options begins with identifying the emission units 
and pollutants that are likely to be regulated. The emission units likely to be regulated under the 
current regulatory approach for the friction materials manufacturing NESHAP are solvent mixers. 
The pollutants to be regulated from these emission units are organic HAP, including n-hexane, 
trichloroethylene, and toluene. 


4-9 


Continuous monitoring of the regulated pollutants or surrogate pollutants is not recommended as a 
means of ensuring continuous compliance with the HAP solvent recovery emission standard. 
Neither of these monitoring options provides a means to measure, directly or indirectly, the solvent 
recovery efficiency. 

Continuous monitoring of selected control device operating parameters allows for real-time 
measurements of parameters that generally are reliable indicators of control device performance. 
The costs of monitoring control device operating parameters are reasonable. The parameter used 

most often as an indicator of condenser performance is outlet gas temperature. For carbon 

% 

adsorbers, the parameters typically monitored include regeneration cycle frequency and steam 
flow. The drawback to this option is that it does not provide adequate information to ensure 
compliance with the solvent recovery standard, considering variations in the quantity of solvent 
added to batches of different product mixes, variations in the amount of solvent remaining in 
different products, and variations in the amount of solvent collected by the system. 

For solvent recovery systems (e.g., carbon adsorbers and condensers), monitoring of solvent usage 
and solvent recovered for each batch allows for measurement of actual solvent recovery 
efficiency. The costs of monitoring these parameters are reasonable. For the proposed standard, 
this would include monitoring the quantity of solvent introduced into the solvent mixer and the 
quantity of solvent recovered by the solvent recovery system. 

4.4 REFERENCES 

1. Memorandum from Bullock, D., Midwest Research Institute, to Cavender, K., ESD/MG. 
Site Visit Report-Plant A. 

2. U. S. Environmental Protection Agency. Toxics Release Inventory for Reporting Year 
1997 for Plant A. 

3. Air Pollution Control Construction and Operation Permits for Plant A. 

4. Memorandum from Bullock, D. and Turner, M., Midwest Research Institute, to Zapata. S.. 
ESD/MICG. Site Visit Report-Plant B. 


4-10 


5. U. S. Environmental Protection Agency. Toxics Release Inventory for Reporting Year 
1998 for Plant B. 

6. Memorandum from Schmitt, D., Bullock, D., and Abraczinskas, M., Midwest Research 
Institute, to Cavender, K., ESD/MG. Site Visit Report-Plant B. 

7. Telecon. Bullock, D. and Abraczinskas, M., Midwest Research Institute, with 
representative of Plant B Solvent recovery process at Plant B. 

8. Information from Plant B to Abraczinskas, M., Midwest Research Institute. Solvent 
recovery process at Plant B. 

9. Memorandum from Schmitt, D. and Turner, M., Midwest Research Institute, to Zapata, S., 
ESD/MICG. Site Visit Report-Plant C. 

10. U. S. Environmental Protection Agency. Toxics Release Inventory for Reporting Year 
1998 for PlantC. 

11. Emission test report for Plant C. 

12. Completed information collection request for Plant D. 

13. U. S. Environmental Protection Agency. Toxics Release Inventory for Reporting Year 
1998 for Plant D. 


4-11 


‘ Chapter 5 

Model Process Unit 

This chapter describes the development of the model process unit for solvent mixers in the friction 
materials manufacturing industry. The model process unit is designed to be representative of 
solvent mixers found at friction materials manufacturing facilities and is used by EPA to estimate 
industry-wide environmental and energy impacts, and costs of control options. These impacts and 
costs are presented in Chapters 6 and 7, respectively. 

Most of the information used in developing the model process unit comes from site visit reports for 
three of the four facilities. 1-3 This information has been supplemented by information from other 
sources, including emission test reports and discussions with industry representatives. 4-7 

5.1 GENERAL APPROACH 

The model process unit exhaust stream parameters that are required for the cost analysis include 
the exhaust gas volumetric flow rate, exhaust gas temperature, and pollutant concentration in the 
exhaust gas stream. Generally, multiple sizes of models are developed (e.g., small, medium, and 
large) to represent the process units. The small population of solvent mixers in the friction 
materials manufacturing industry and the limited data available do not support developing multiple 
models for solvent mixers. Therefore, one solvent mixer model was developed. Also, because of 
the limited available data, a simple approach was taken in choosing the model process unit exhaust 
stream parameters. For parameters where only a single data point was available (e.g., pollutant 
concentration in the exhaust stream), the single data point was used for the model process unit. For 
parameter-' where multiple data points were available (e.g., exhaust gas flow rate and exhaust gas 
temperature), the arithmetic average of the data points (rounded to two significant figures) was 
used to represent the model process unit parameters. 


5-1 


A model process unit was developed only for solvent mixers; no other models were developed 
because no other emission units will be regulated under the proposed standard for friction 
materials manufacturing. The model solvent mixer is characterized by the stack gas parameters 
mentioned above, and VOC concentration. The VOC concentration is used as a surrogate for the 
oiganic HAP concentration because actual HAP concentration data are not available. Section 5.2 
describes the development of the model solvent mixer. Chapter 2 describes solvent mixers in 
more detail. 

« 

% 

5.2 SOLVENT MIXERS 

There are seven solvent mixers in operation at the four friction materials manufacturing facilities 
estimated to be major sources. Of these four facilities, one facility operates four solvent mixers, 
and the other three facilities operate a single solvent mixer each. The HAPs emitted from solvent 
mixers include n-hexane, toluene, and trichloroethylene. Based on available data, a given facility 
uses only one of these three solvents. Therefore, emissions from any single solvent mixer would 
include only one of the above compounds. 

The controlled solvent mixers for which data are available are controlled by dedicated solvent 
recovery systems (i.e., one solvent recovery system for one mixer). The solvent mixers that 
represent the MACT floor and beyond-the-floor are each characterized as having a closed-vent 
system with a low-volume, high-concentration exhaust stream ducted to a condenser. It is assumed 
that the four existing uncontrolled solvent mixers will be enclosed in order to vent emissions to a 
condenser. The solvent mixer model process unit has been developed to reflect this application. 

Table 5-1 presents the limited available data for closed-vent solvent mixer exhaust parameters. 
Because inlet concentration data were available for only one of the solvents used, Antoine’s 
equation was used to calculate the inlet concentrations for the three solvents at the model 
temperature, assuming a saturated stream. 8 As a check of the reasonableness of assuming a 
saturated stream, Antoine’s equation was also used to calculate the inlet concentration for the one 
facility where an inlet value was available. Using the actual temperature of that stream, the 
calculated inlet concentration is within approximately 10 percent of the actual value. 


5-2 


Table 5-1. Exhaust Stream Characteristics for Closed-Vent Solvent Mixer Systems 


Facility 

Flow rate 
(dscfm) 

Exhaust stream 
temperature (°F) 

VOC concentration 
(ppm) 

Plant A 

50 

145 

— 

Plant B 

39 

110 

456,206 

Average: 

45 

128 

456,206 




Table 5-2 presents a summary of the model process unit exhaust parameters for closed-vent 
solvent mixers based on the data in Table 5-1 and the calculated inlet concentrations for each 
solvent. 


Table 5-2. Model Process Unit Exhaust Parameters for Closed-Vent Solvent Mixer Systems 


Parameter 

Model Process Unit Value 

Flow rate (dscfm) 

45 

Exhaust stream temperature (°F) 

130 

Calculated volume fraction of solvent in the exhaust stream at 


saturation: 3 


n-hexane 

0.62 

trichloroethylene 

0.33 

toluene 

0.15 


a Volume fractions are for exhaust streams containing only one of the listed compounds. Based on available data, 
a given mixer uses only one of the three listed solvents. 


5.2 REFERENCES 

1. Memorandum from Bullock, D., Midwest Research Institute, to Cavender, K., ESD/MG. 
Site Visit Report-Plant A. 

2. Memorandum from Bullock, D. and Turner, M., Midwest Research Institute, to Zapata, S., 
ESD/MICG. Site Visit Report-Plant B. 

3. Memorandum from Schmitt, D. and Turner, M., Midwest Research Institute, to Zapata, S., 
ESD/.MICG. Site Visit Report- Plant C. 

4. Tqlecon. Bullock, D. and Abraczinskas, M., Midwest Research Institute, with 
representative of Plant A. Solvent mixer and condenser system. 


5-3 

























5. Telecon. Bullock, D. and Abraczinskas, M., Midwest Research Institute, with 
representative of Plant A. Solvent mixer condenser system and mixing process. 

6. Telecon. Bullock, D. and Abraczinskas, M., Midwest Research Institute, with 
representative of Plant B. Solvent mixer and recovery system. 

7. Telecon. Abraczinskas, M., Midwest Research Institute, with representative of Plant C. 
Solvent mixing process. 

8. Memorandum from Randall, D., Midwest Research Institute, to project file. Volume 
Fraction of Solvents. October 19, 2000. 


5-4 


*■ Chapter 6 

Environmental and Energy Impacts 

This chapter presents the environmental and energy impacts associated with controlling HAP 
emissions from solvent mixers in the friction materials manufacturing source category. 
Environmental impacts include primary and secondary air pollution impacts, water impacts, and 
solid waste impacts, while energy impacts include electricity requirements. Environmental and 
energy impacts were estimated for the control technique (solvent recovery system) likely to be 
used to control emissions to the MACT floor and beyond-the-floor control levels for solvent 
mixers. 

Four friction materials manufacturing facilities were included in the MACT floor and beyond-the- 
floor analyses. The potential and baseline HAP emissions and characterization of HAP emission 
sources are provided in Chapter 2. The MACT floor and beyond-the-floor control options for 
existing and new solvent mixers are provided in Chapter 4. The development of the model 
process unit is described in Chapter 5. The emission estimation approach is described in 
Appendix B. 

This chapter contains seven sections. Section 6.1 discusses the basis for the environmental and 
energy impacts analysis. Section 6.2 discusses the primary air pollution impacts. Section 6.3 
discusses the secondary air pollution impacts. Section 6.4 discusses the water pollution impacts. 
Section 6.5 discusses the solid waste disposal impacts. Section 6.6 discusses the energy impacts. 
Section 6.7 provides a list of references. 


6-1 


6.1 BASIS FOR IMPACTS ANALYSIS 

This environmental and energy impacts analysis assumes that solvent mixers will be retrofitted 
with condensers to control HAP emissions. This assumption is based on control techniques 
demonstrated by friction materials manufacturing facilities. For the purposes of this analysis, it is 
assumed that the four existing uncontrolled solvent mixers will be retrofitted with condensers in 
order to meet the MACT floor and beyond-tbe-floor levels. It is also assumed that one existing 
solvent mixer currently controlled to the MACT floor level of 70 percent will have to install a 
more efficient condenser to meet the beyond-the-floor level of 85 percent. This analysis also 
assumes that multiple solvent mixers will not share a condenser. 

Data on the number of motor vehicles in use and locomotives and railcars in use 1 were used to 
project the change in the demand for friction materials over the next 5 years (i.e., from 2001 to 
2006). 1 Based on the available data, an 8 percent increase in motor vehicles, locomotives, and 
railcars in use is expected over the next 5 years. This increase is believed to be indicative of a 
similar increase in the demand for friction materials. The annual growth rate in friction materials 
sales over the next 5 years is estimated to be approximately 14 percent.' The number of new 
solvent mixers is assumed to correlate to the increase in friction matenals production and sales. 
Because the overall average production capacity utilization for the friction matenals manufacturing 
industry is approximately 50 percent, the current industry capacity is more than sufficient to meet 
the increased demand. Therefore, it is projected that no new solvent mixers will be installed. 

6.2 PRIMARY AIR POLLUTION IMPACTS 

Primary air pollution impacts consist of the reduction of n-hexane and toluene emissions relative to 
the baseline level directly attributable to the implementation of the control options. (No reduction 
in trichloroethylene [TCE] emissions is expected at the MACT floor or beyond the floor because 
the facility using this solvent is already in compliance with the beyond-the-floor control option.) 
The MACT floor control option is estimated to reduce HAP emissions from existing friction 
materials manufacturing facilities by approximately 200 tpy, or 31 percent, from a baseline HAP 
emission level of approximately 640 tpy. The beyond-the-floor control option is estimated to 
reduce HAP emissions by approximately 310 tpy, or 49 percent, relative to the baseline level. A 


6-2 


summary of the primary air impacts associated with implementation of the MACT floor and 
beyond-the-floor control options is shown in Table 6-1. 


Table 6 -1. Nationwide Primary Air Impacts for Existing Friction Materials 

Manufacturing Facilities 


Control level 

Pollutant 

Emissions, tpy 3 

Emission 
reduction, tpy 

Percent 

reduction 

Baseline 

Post-MACT 

MACT floor 

n-Hexane 

560 

380 

170 

31% 

Toluene 

63 

36 

27 

56% 

TCE 

18 

18 

0 

0% 

Total HAP 

640 

440 

200 

31% 

Beyond the floor 

n-Hexane 

560 

280 

280 

50% 

Toluene 

63 

30 

33 

68% 

TCE 

18 

18 

0 

0% 

Total PIAP 

640 

330 

310 

49% 


a The baseline emissions are based on emissions from the four facilities estimated to be major sources and 


equipped with HAP solvent mixers. 

6.3 SECONDARY AIR POLLUTION IMPACTS 

Secondary air pollution impacts consist of any adverse or beneficial air impacts other than the 
primary air impacts described in Section 6.2. The secondary impacts are impacts that result from 
the operation of any new or additional add-on control devices (e.g., condensers). 

Secondary air impacts consist of: (1) byproducts generated from the fuel combustion necessary to 
generate the electricity required to operate the control devices, and (2) VOC emissions reduced 
due to the implementation of the control options. The estimated electricity requirements are 
described in Section 6.6. The electricity is assumed to be generated at coal-fired utility plants 
built since 1978. These plants are subject to the new source performance standards (NSPS) in 
subpart Da of 40 CFR pan 60. These NSPS emission limits were used to estimate secondary 
emissions of sulfur dioxide (S0 2 ), nitrogen oxides (NO x ), and PM with an aerodynamic diameter 
at or below 10 micrometers (PM 10 ) from coal combustion. 


6-3 






















Because carbon monoxide (CO) emissions are not covered by the NSPS, the CO emission factor 
for bituminous/subbituminous coal combustion from the AP-42 was used to estimate the CO 
secondary emissions. The CO secondary emissions were estimated assuming an average heating 
value of 14,000 British thermal units per pound (Btu/lb) of bituminous/subbituminous coal. 


A summary of the estimated secondary air impacts is presented in Table 6-2. It is estimated that 

Jr 

the MACT floor control option will increase byproduct emissions from fuel combustion from 
utility plants by less than 0.3 tpy, while the beyond-the-floor control option will increase 
byproduct emissions by less than 0.5 tpy. 


Table 6-2. Nationwide Secondary Air and Energy Impacts for 
Existing Friction Materials Manufacturing Facilities 


Control level 

Model 

Increased emissions, tpy a 

Increased 

electricity, 

MMBtu/yr 

so 2 

NO x 

PM.o 

CO 

MACT floor 

Solvent mixers (n- 
hexane) 

0.17 

0.069 

0.0041 

0.0025 

280 

Solvent mixers 
(toluene) 

0.018 

0.0074 

0.0004 

0.0003 

30 

Solvent mixer 
(TCE) 

0 

0 

0 

0 

0 

Total 

0.18 

0.076 

0.0046 

0.0027 

300 

Beyond the 
floor 

Solvent mixers (n- 
hexane) 

0.29 

0.12 

0.0073 

0.0044 

490 

Solvent mixers 
(toluene) 

0.024 

0.0099 

0.0006 

0.0004 

39 

Solvent mixer 
(TCE) 

0 

0 

0 

0 

0 

Total 

0.32 

0.13 

0.0079 

0.0047 

530 


The S0 2 , NO x , and PM I0 emissions were estimated using the NSPS emission limits of 1.2 lb S0 2 , 0.5 lb NO x , 
and 0.03 lb PM 10 per MMBtu fuel input for coal-fired utility plants. The CO emissions were estimated using the 
AP-42 emission factor of 0.5 lb CO/ton of coal for bituminous and subbituminous coal combustion. 


In addition to the generation of byproduct emissions from fuel combustion, secondary’ air impacts 
also include the reduction of VOC emissions from the implementation of the control options. The 
VOC compounds are precursors to tropospheric ozone formation. Emissions of VOC will be 
reduced by approximately 200 tpy at the MACT floor and 310 tpy beyond the floor. These VOC 


6-4 
























emission reductions are identical to the primary organic HAP emission reductions because the 
organic HAP reduced by the control options are also classified as VOC. 

6.4 WATER POLLUTION IMPACTS 

Friction materials manufacturing facilities impacted at the MACT floor or beyond the floor are 
expected to install condensers with glycol rather than chilled water as the cooling medium. 
Therefore, no water pollution impacts are expected with the implementation of either the MACT 
floor or beyond-the-floor option. 

% 

% 

6.5 SOLID WASTE DISPOSAL IMPACTS 

Friction materials manufacturing facilities impacted at the MACT floor or beyond the floor are 
expected to install condensers to comply with the control options. Because condensers do not 
generate solid waste, no solid waste disposal impacts are expected with the implementation of 
either the MACT floor or beyond-the-floor option. 

• 

6.6 ENERGY IMPACTS 

Energy impacts consist of the electricity required to operate the control devices (condensers) used 
to comply with the control options. As noted in section 6.3, electricity is assumed to be generated 
in coal-fired boilers at utility plants. The amount of fuel energy required to generate the electricity 
was estimated using a heating value of 14,000 Btu/lb of coal and a utility plant efficiency of 35 
percent. The electricity requirements were estimated by dividing the electricity costs for each of 
the control devices by the unit cost for electricity ($0.06 per kilowatt-hour [kWh]) used in the cost 
analyses, converting to million British thermal units (MMBtu), and multiplying by the number of 
impacted units for each model process unit. Table 6-2 presents the annual electricity impacts 
associated with operating the control devices. The overall energy demand (i.e., electricity) is 
expected to increase by approximately 300 MMBtu/yr nationwide at the MACT floor and 530 
MMBtu/yr beyond the floor. 

6.7 REFERENCES 

1. Memorandum from Bullock, D., Midwest Research Institute, to project file. May 17, 2001. 
New Source Projections for the Friction Materials NESHAP. 


6-5 


Chapter 7 
Cost of Controls 


This chapter presents the estimated costs associated with controlling HAP emissions from solvent 
mixers in the friction materials manufacturing source category. Costs were estimated for the 
control technique likely to be used to control emissions to the MACT floor and beyond-the-floor 
control levels for solvent mixers, as well as for testing, monitoring, reporting, and recordkeeping 
requirements. 

Four friction materials manufacturing facilities were included in the MACT floor and beyond-the- 
floor analyses. The MACT floor and beyond-the-floor control options for existing and new 
solvent mixers are provided in Chapter 4. The development of the model process unit is described 
in Chapter 5. In addition, estimates of baseline emissions and emission reductions achieved under 
the MACT floor and beyond-the-floor control options are provided in Chapter 6. 

This chapter contains eight sections. Section 7.1 discusses the basis for the control cost analysis. 
Section 7.2 discusses the estimated control device costs. Section 7.3 discusses the costs 
associated with initial compliance (performance tests and compliance demonstrations). 

Section 7.4 discusses the estimated monitoring costs. Section 7.5 discusses the estimated 
repo, ting and recordkeeping costs. Section 7.6 discusses the cost effectiveness of the MACT floor 
and beyond-the-floor control options. Section 7.7 discusses the estimated number of new sources. 
Section 7.8 discusses the estimated cost impacts on small businesses. Section 7.9 provides a list 
of references. 


7-1 


7.1 BASIS FOR CONTROL COST ANALYSIS 

The controlled solvent mixers for which data are available are controlled by dedicated solvent 
recovery systems (e.g., one condenser or carbon adsorber per mixer). The solvent mixers that 
represent MACT floor and beyond-the-floor control are enclosed (i.e., sealed and under vacuum) 
and have low-volume, high-concentration exhaust streams controlled with a condenser. In order to 
m£et the MACT floor and beyond-the-floor control levels, it is assumed that the four uncontrolled 
solvent mixers will be enclosed in order to-vent emissions to a comparable solvent recovery 
system (e.g., a condenser). The solvent mixer model process unit has been developed to reflect 

this application. It is also assumed that one existing solvent mixer currently controlled to the 

% 

MACT floor level of 70 percent will have to install a more efficient condenser to meet the 
beyond-the-floor level of 85 percent. 

A condenser is the likely choice for the low-volume, high-concentration exhaust stream 
represented by the model. For applications having a high-volume, low-concentration exhaust 
stream (i.e., solvent mixers that are not enclosed), a carbon adsorber may be a viable option. 

The control cost algorithm for the condenser is based on the control cost algorithm developed by 
EPA’s Office of Air Quality Planning and Standards (OAQPS). 1 The assumptions and data used in 
the algorithm were generated following guidelines in the OAQPS Control Cost Manual. The 
refrigeration unit size (tons of cooling) is based on an energy balance around the unit when the 
process is venting and the inlet stream contains its maximum HAP load. Costs were developed for 
single-stage refrigeration units using the approach in the OAQPS Control Cost Manual. 

The purchased equipment cost (PEC) for the refrigeration system is equal to the total equipment 
cost plus 18 percent for instrumentation, sales tax, and freight. The installation cost for the 
refrigeration system includes both direct and indirect installation costs. The direct installation 
cost for the refrigeration system is equal to the PEC for the system plus 43 percent for foundations 
and supports, handling and erection, electrical installation, piping installation, insulation for 
ductwork and painting. The indirect installation cost for the refrigeration system is equal to the 
PEC for the system plus 31 percent for engineering, construction and field expenses, contractor 
fees, start-up, performance test, and contingencies. 


7-2 


The total capital cost is equal to the sum of the PEC for the refrigeration system, direct and indirect 
installation costs of the refrigeration system. In estimating the total capital cost for control device 
equipment, the equipment costs were based on data from various years and were scaled to 
represent costs in December 2000 dollars. 

The total annual cost for the condenser consists of direct annual costs, indirect annual costs, and 
recovery credits. Direct annual costs are costs for labor, maintenance materials, and electricity. 

Indirect annual costs are.costs for overhead, administrative charges, property taxes, insurance, and 

% 

capital recovery. Recovery credits are credits for the value of the recovered solvent and represent 
the savings due to reduced solvent purchases. The unit costs and other factors used to estimate 
these costs and credits are given in Table 7-1. 


Table 7-1. Assumptions for Annual Cost Calculations 


Direct annual costs 

Operator labor wage rate 

$19.72 per hour, based on December 2000 wage rate for 
Manufacturing: Transportation Equipment (Monthly 
Labor Review, Bureau of Labor Statistics) 

Maintenance labor wage rate 

$21.69 per hour, based on 110 percent of operator labor 
wage rate 

Supervisor labor cost 

15 percent of operator labor cost 

Maintenance materials cost 

100 percent of maintenance labor cost 

Maintenance labor requirements 

0.5 hour per 8-hour operation 

Electricity unit cost 

$0.06 per kWh 

Indirect annual costs 


Overhead 

60 percent of all labor and maintenance material costs 

Administrative changes, property 
taxes, and insurance 

4 percent of total capital cost 

Capital recovery (condenser) 

Capital recover)' factor (CRF) times the total capital 
cost. The CRF is 0.1098, based on a 15-year equipment 
life and 7 percent interest rate. 

Recovery credits 

n-Hexane 

$0.26 per lb 

Toluene 

$0.28 per lb 


7-3 






















Electricity requirements for the refrigeration unit were estimated using the tabulated data in the 
OAQPS Control Cost Manual. Linear regression was used to develop an equation for electricity 
requirements per ton of cooling as a function of the condenser temperature. The mechanical 
efficiency of the compressor was estimated to be 85 percent. Electricity requirements for pumps 
and blowers were considered to be negligible relative to the requirements for the refrigeration 
unit. 

7.2 CONTROL DEVICE COSTS 

% 

Table 7-2 presents a summary of the estimated capital and annual control costs for condensers 
installed on individual solvent mixers. Annual costs are presented without recovery credits. 
Separate costs are presented for systems recovering toluene and n-hexane and for the MACT floor 
and beyond-the-floor control requirements. Total facility control costs were estimated assuming 
that separate recovery systems will be installed for each solvent mixer. 


Table 7-2. Control Costs for Condensers Installed on Individual Solvent Mixers 


Control level 

Solvent used 

Capital cost, $ 

Annual cost, $/year a 

MACT floor 1 ’ 

n-Hexane 

$39,000 

$19,000 

Toluene 

$28,000 

$16,000 

Beyond the floor c 

n-Hexane 

$50,000 

$21,000 

Toluene 

$37,000 

$18,000 


a Annual costs do not include solvent recovery credits. 

b Condenser costs were estimated at 74 percent efficiency to achieve MACT floor level of 70 percent recovery. 
c Condenser costs were estimated at 90 percent efficiency to achieve beyond-the-floor level of 85 percent 


recovery. 

The total capital control costs for the industry are estimated to be approximately $150,000 at the 
MACT floor and $240,000 beyond the floor. The total annual control costs for the industry, 
without recovery credits, are estimated to be approximately $72,000 at the MACT floor and 
$100,000 beyond the floor. The total annual control costs for the industry, including recovery 
credits, are estimated to be net credits of approximately $33,000 at the MACT floor and $62,000 
beyond the floor. 2 


7-4 















7.3 INITIAL COMPLIANCE COSTS 

No performance testing would be required under the NESHAP for friction materials 
manufacturing. Therefore, there are no costs associated with performance testing. - However, an 
initial compliance demonstration would be required under the friction materials manufacturing 
. NESHAP. The initial compliance demonstration would consist of monitoring and recording the 
weight of HAP solvent delivered into each solvent mixer and recovered from each mix batch over 
the first 7 consecutive days after the compliance date. Because this is also a monitoring activity, 
the costs associated with the initial compliance demonstration are included in the monitoring costs 
presented in the following section. 

7.4 MONITORING COSTS 

The friction materials manufacturing NESHAP would include requirements for monitoring and 
recording the weight of HAP solvent delivered into solvent mixers and recovered from each mix 
batch. Capital costs include costs for an industrial floor scale system to weigh the solvent loaded 
into and recovered from the mixer, digital meter, installation, taxes, and freight. The total capital 
cost for a scale system is estimated to be approximately $2,100. ? Annual costs include costs for 
operating and maintenance labor, maintenance materials and supplies, taxes, insurance, 
administrative charges, and capital recover}'. The total annual cost for a scale system is estimated 
to be approximately $3,700. ? Facility monitoring costs were estimated assuming that separate 
scale systems will be installed and operated for each solvent mixer. Total capital monitoring 
costs for the industry are estimated to be approximately $13,000 and total annual monitoring costs 
are estimated to be approximately $22,000, both at the MACT floor and beyond the floor. 2 

7.5 REPORTING AND RECORDKEEPING COSTS 

The proposed friction materials manufacturing NESHAP includes requirements for reporting and 
recordkeeping. Capital reporting and recordkeeping costs include costs for file cabinets for 
storing records. The total capital cost for the industry is estimated to be $940. 2 Annual reporting 
and recordkeeping costs include labor costs for reporting and recordkeeping, annualized capital 
costs for trie file cabinets, and operation and maintenance costs for photocopying and postage 
associated with the reporting requirements. The total annual cost for the industry is estimated to be 


7-5 


approximately $80,000. 2 These costs do not include costs associated with monitoring, which are 
discussed in the previous section. 

7.6 COST EFFECTIVENESS 

The cost effectiveness of the MACT floor and beyond-the-floor control options for friction 
materials manufacturing is estimated as the total annual cost of the control option (control cost, 
monitoring cost, and reporting and recordkeeping cost) divided by the amount (tpy) of HAP 
recovered, which yields a cost per ton of HAP recovered. Table 7-3 presents the total HAP 
emission reduction, total-annual costs, and the associated cost effectiveness. The cost 
effectiveness of controlling HAP solvent emissions from existing solvent mixers at major sources, 
without recovery credits, is estimated to be approximately $890/ton at the MACT floor and 
$660/ton beyond the floor. The cost effectiveness of controlling HAP solvent emissions from 
existing solvent mixers at major sources, including recovery credits, is estimated to be 
approximately $360/ton at the MACT floor and $ 140/ton beyond the floor. 


Table 7-3. Nationwide Cost-effectiveness for Existing 
Friction Materials Manufacturing Facilities 


Control level 

Nationwide annual cost, $/yr 

Emission 
reduction from 
baseline, tpy 

Cost effectiveness, $/ton 

Without 

credits 

With 

credits 

Without 

credits 

With 

credits 

MACT floor 

$180,000 

$72,000 

200 

$890 

$360 

Beyond the floor 

$210,000 

$43,000 

310 

$660 

$140 

Incremental 

$29,000 

($29,000) 

110 

$260 

($260) 


The incremental cost effectiveness of going from the MACT floor to beyond the floor for friction 
materials manufacturing is estimated as the difference in the annual cost of the control options 
divided by the difference in the number of tons of HAP recovered, which yields an incremental 
cost per ton of HAP recovered. Table 7-3 presents the incremental HAP emission reduction, 
incremental total annual cost, and the associated incremental cost effectiveness. The incremental 
cost effectiveness of going from the MACT floor to beyond the floor is estimated to be 
approximately $260/ton, without recovery credits, and a net credit of approximately $260/ton, 
with recovery credits. 


7-6 

















7.7 NEW SOURCES 

Data on the number of motor vehicles in use and locomotives and railcars in use were used to 
project the change in the demand for friction materials over the next 5 years (i.e., from 2001 to 
2006). 3 Based on the available data, an 8 percent increase in motor vehicles, locomotives, and 
railcars in use is expected over the next 5 years. This increase is believed to be indicative of a 
similar increase in the demand for friction materials. The annua! growth rate in friction materials 
sales over the next 5 years is estimated to be approximately 14 percent. 3 The number of new 
solvent mixers is assumed to correlate to the increase in friction materials production and sales. 
Because the overall average production capacity utilization for the friction materials industry is 
approximately 50 percent, the current industry capacity is more than sufficient to meet the 
increased demand. Therefore, it is projected that no new solvent mixers will be installed. 
Consequently, there are no costs associated with new solvent mixers. 

7.8 SMALL BUSINESSES 

One small business is included in the population of facilities used for evaluating and determining 
the MACT floor and beyond-the-floor control levels. This facility is estimated to be a major 
source of HAP emissions and will have to meet the requirements of the friction materials 
manufacturing NESHAP. This facility already has a solvent recovery system (condenser) in place 
that can meet both the MACT floor and beyond-the-floor control levels. In addition, this facility 
has the necessary monitoring equipment in place. The total annual cost for this facility is estimated 
to be approximately $21,000, which is comprised entirely of reporting and recordkeeping costs. 

7.9 REFERENCES 

1. U. S. Environmental Protection Agency. OAQPS Control Cost Manual. Fifth Edition. 
EPA/453/B-96-001. February'1996. Chapter 8. Refrigerated Condensers. 

« 

2. Memorandum from Bullock, D., Hanks, X., and Holloway, T., Midwest Research Institute, 
to project file. July 24, 2001. Facility-Specific Costs for the Friction Materials 
Manufacturing Industry. 

3. Memorandum from Hanks, K., Midwest Research Institute, to project file. May 17, 2001. 
Monitoring Costs for the Friction Materials Manufacturing NESHAP. 


7-7 


4. 


Memorandum from Bullock, D., Midwest Research Institute, to project file. May 17, 2001. 
New Source Projections for the Friction Materials Manufacturing NESHAP. 


7-8 


Appendix A 

Evolution of the Standard 

This appendix summarizes the background information gathered and the analyses performed during 
the development of the friction materials manufacturing standard. In developing the standard, the 
following technical data were acquired from the friction materials manufacturing industry: 

(1) equipment design and operating parameters, (2) types and quantities of HAP emitted, (3) 
emission reduction techniques, and (4) the effectiveness of these control techniques in reducing 
HAP emissions. The bulk of the information was gathered from the following sources: 

1. Technical literature; 

2. Industry'representatives; 

3. Site visit reports; 

4. ICRs; 

5. State and local air pollution control agencies; and 
4. Emission test reports. 

Significant events relating to the evolution of the friction materials manufacturing standard 
are listed in Table A-l. 


Table A-l. Evolution of the Standard 


Date 

Event 

4/1/97 

Draft memo summarizing existing friction products information submitted to EPA 

4/3/97 

Site visit to Stone Heavy Vehicle Specialists, Inc., Raleigh, North Carolina 

4/24/97 

Site visit to Quality Automotive Co., Tappahannock, Virginia 

4/25/97 

Site visit to VAAPCO, Inc.. Millers Tavern, Virginia 

5/1/97 

Site visit to The Hastings Co., King, North Carolina 

6/11/97 

Final site visit reports for Stone Heavy Vehicle Specialists, Inc., Raleigh, North Carolina and 

The Hastings Co., King, North Carolina 


A-l 














Table A-1. (continued) 


Date 

Event 

6/24/97 

Meeting with representatives of the friction products industry to discuss the friction products 
MACT standards development project, including diaft ICR 

8/27/97 

Draft memo comparing generic ICR questionnaire with friction products ICR questionnaire 
submitted to EPA 

9/4/97 

Final site visit report for VAAPCO, Inc., Millers Tavern, Virginia 

9/23/97 

Site visit to Performance Friction Corp., Clover, South Carolina 

11/7/97 

ICR questionnaires mailed out to friction products industry (responses due 60 days after 
mailout) 

12/12/97 

First site visit to Railroad Friction Products Corp., Laurinburg, North Carolina 

1/2/98 

Final site visit report for Performance Friction Corp., Clover, South Carolina 

1/16/98 

Data base created to tabulate information in the ICR responses; responses (ICRs, 
delay/ex'ension letters, not applicable letters) received for over 50 percent of mailouts by 
deadline; updated docket index submitted to EPA 

2/27/98 

Memo describing current plans for emission testing at friction products facilities submitted to 

EPA 

3/12/98 

Updated docket index submitted to EPA 

5/7/98 

Updated docket index submitted to EPA 

5/11/98 

Final site visit report for Quality Automotive Co., Tappahannock, Virginia 

6/18/98 

Updated docket index submitted to EPA 

7/22/98 

.Site visit to BF Goodrich Aerospace, Pueblo, Colorado 

7/30/98 

Updated docket index submitted to EPA 

8/4/98 

Site visit to Federal-Mogul, Smithville, Tennessee 

8/25/98 

Final site visit report for first trip to Railroad Friction Products Corp., Laurinburg, North 

Carolina 

8/27/98 

All expected ICR responses/clarifications (97 percent) received; updated docket index 
submitted to EPA 

10/8/98 

Updated docket index submitted to EPA 

10/21/98 

Site visit to Raybestos Products Co., Crawfordsville, Indiana 

12/11/98 

Data entry' of ICR responses complete (about 90 percent of available data sets); poor ICR 
responses (about 10 percent) not entered 

12/11/98 . 

Updated docket index submitted to EPA 

1/19/99 

Final site visit report for Raybestos Products Co., Crawfordsville, Indiana 

2/8/99 

Friction products National Toxics Inventory (NTI) template submitted to EPA 


A-2 




































Table A-1. (continued) 


Date 

Event 

7/8/99 

Updated friction products NTI template submitted to EPA 

V 14/00 

Second site visit to Railroad Friction Products Corp., Laurinburg, North Carolina 

3/8/00 

Draft BID Chapter 1 (Introduction) submitted to EPA 

3/17/00 

Draft outline of BID submitted to EPA 

4/5/00 

Draft BID Chapter 2 (Industry Profile) submitted to EPA 

4/13/00 

% 

Meeting with EPA to review MACT floors 

4/19/00 

Final site visit report for BF Goodrich Aerospace, Pueblo, Colorado 

4/26/00 

Draft BID Chapter 3 (Emission Control Techniques) submitted to EPA 

5/31/00 

Draft BID Chapter 4 (MACT Floors and Regulatory Options) submitted to EPA 

6/13/00 

Meeting with EPA to review model process units; draft Appendix B to BID (Emission 

Estimation Methodology) submitted to EPA 

6/30/00 

Draft BID Chapter 5 (Model Process Units) submitted to EPA 

7/13/00 

Meeting with EPA to discuss economics-related issues for friction products MACT standard 

8/17/00 

Drafts of BID Chapters 6 (Environmental and Energy Impacts) and 7 (Cost of Controls) 
submitted to EPA 

10/26/00 

Draft proposal regulation submitted to EPA 

11/9/00 

Site visit to Thermoset, Inc., Jackson, Wisconsin 

11/14/00 

Non-CBI test report summary submitted to EPA for review by facilities 

11/16/00 

Meeting w'ith representatives of the friction products industry to update the industry on the 
status of the friction products MACT standards development project 

12/22/00 

Draft proposal preamble submitted to EPA 

1/16/01 

Draft new' source projections memo submitted to EPA; draft monitoring costs memo submitted 
to EPA 

2/6/01 

Draft memo transmitting facility-specific cost estimates submitted to EPA/ISEG; draft OMB 

83-1 and supporting statement submitted to EPA 

3/27/01 

Final site visit report for Thermoset, Inc., Jackson, Wisconsin 

4/17/01 

Final site visit report for second trip to Railroad Friction Products Corp., Laurinburg. North 
Carolina 

4/27/01 

Final site visit report for Federal-Mogul, Smithville, Tennessee 

5/8/01 

Final facility-specific cost estimates submitted to EPA 

5/10/01 

Final OMB 83-1 and supporting statement submitted to EPA 

6/11/01 

Revised draft BID Chapters 1-7 and Appendices A and B submitted to EPA 


A-3 













































Table A-1. (continued) 


Date 

Event 

8/3/01 

Final draft BID submitted to EPA 


* 

\ 


A-4 









Appendix B 

Emission Estimation Methodology 



This appendix presents the methodologies used in estimating HAP emissions from facilities in the 
friction materials manufacturing industry. The methodologies for estimating uncontrolled and 
controlled emissions are presented, as well as the methodologies for estimating emissions 
associated with the MACT floor and beyond-the-floor options. The emissions estimates are 
presented in Tables B-l through B-4 below. Emissions were estimated for the four friction 
materials manufacturing facilities (Plants A, B, C, and D) with resin-based processes that are 
major sources of HAP emissions. Sections B.l through B.4 present the emission estimation 
methodologies for these four facilities. Section B.5 provides a list of references, 

B.l Plant A 

B.1.1 Baseline and Uncontrolled Emissions 

Uncontrolled emissions from Plant A were determined based on the annual consumption of toluene 

solvent, assuming that the quantity of solvent consumed is equal to the quantity of solvent emitted. 

According to the ICR response for Plant A, the annual consumption of toluene solvent for 1997 

was expected to be 13,085 gal, and the HAP content of the solvent is 100 percent; this is 

equivalent to an annual consumption of 46.98 tpy for toluene, based on a reported density of 7.18 

lb/gal. 5 Therefore, the total uncontrolled emissions for Plant A were estimated to be 46.98 tpy. 

« 

Using the equipment ratios from Plant B as a model (80.5 percent from solvent mixer, 10.5 percent 
from extruder, 7.2 percent from granulator, 1.6 percent from dryers, and 0.2 percent from hot 
presses), 80.5 percent of the uncontrolled emissions at Plant A were assumed to be from the 
solvent mixer, and 10.5 percent were assumed to be from the extruder. Emissions from the oven 


B-l 


were assumed to be equivalent to the remainder of the emissions (9.0 percent). Therefore, the 
uncontrolled emissions for the solvent mixer were estimated to be 0.805 * 46.98 tpy = 37.82 tpy, 
while the uncontrolled emissions for the rest of the solvent mixer line (extruder and oven) were 
estimated to be 0.195 * 46.98 tpy = 9.16 tpy. 

Baseline emissions for the solvent mixer were estimated based on the effectiveness of the vacuum 
system used to capture and collect the toluene solvent and the control efficiency of the condenser 
used to recover the toluene solvent. Based on the available data, Plant A’s vacuum system 
captures 95 percent of the toluene from the solvent mixer, and the condenser recovers 90 percent 
of the captured solvent vapor, resulting in an overall solvent recovery of 85 percent, which the 
facility has consistently achieved. 6 Therefore, baseline emissions for the solvent mixer were 
estimated to be 0.15 * 37.82 tpy = 5.67 tpy. Because the rest of the solvent mixer line (extruder 
and oven) is uncontrolled, the emissions from these pieces of equipment would remain unchanged 
(9.16 tpy). 

B.1.2 MACT Floor and Beyond-the-Floor Emissions 

The MACT floor and beyond-the-floor emissions for Plant A would be identical to baseline 
emissions because the solvent mixer at this facility already achieves 85 percent solvent recovery. 
Therefore, this solvent mixer is not impacted at the MACT floor and beyond-the-floor. 

B.2 Plant B 

B.2.1 Baseline and Uncontrolled Emissions 

Baseline emissions from Plant B were determined based on the quantity of hexane solvent 
purchased, assuming that the quantity of solvent purchased is equal to the quantity of solvent 
emitted. According to the response to the ICR for Plant B, the annual purchase of hexane solvent 
for 1997 was expected to be 317,914 gallons (gal), and the n-hexane content of the solvent 
purchased was 62.3 percent. 1 Using a reported density of 5.619 pounds per gallon (lb/gal) for n- 
hexane, this is equivalent to baseline emissions of 556.45 tpy of n-hexane for Plant B. 1 


B-2 


Table B-l. Facility-Specific Uncontrolled HAP Emissions 



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B-3 
























































Table B-3. Facility-Specific MACT Floor HAP Emissions (MACT Floor Level of Control = 70 Percent) 


MACT floor HAP emissions, tpy 

Oven 

4.23 

000 

000 

000 

4.32 

000 


d At Plant C, estimated 85 percent control at solvent mixer; control efficiency is 94 percent; capture efficiency unknown, assumed to be 90 percent. 

Table B-4. Facility-Specific Beyond-the-Floor HAP Emissions (Beyond-the-Floor Level of Control = 85 Percent) 

Beyond-the-floor HAP emissions, tpy 

Oven 

4.23 

000 

000 

000 

4.32 

000 


Press 

j 

1.14 

190 

1.76 

7.07 

0.24 


Press 

i 

i 

1.14 

190 

1.76 

7.07 

0.24 


Dryer 

! 

9.13 

4.92 

14.05 

l 

l 

1.38 


Dryer 

I 

I 

9.13 

4.92 

14.05 

i 

l 

OO 

m 


Granulator 

i 

i 

41.09 

22.13 

63.22 

! 

l 

I 

- 

Granulator 

1 

l 

41.09 

22.13 

63.22 

i 

i 

i 

i 


Extruder 

m 

O) 

« 

m 

O' 

os 

32.27 

92.20 

i 

7.68 

% 

Extruder 

4.93 

59.93 

32.27 

0ZZ6 

i 

7.68 


Mixer 

5.67 

137.83 

74.22 

212.05 

7.05 

11.52 


Mixer 

5.67 

68.92 

37.11 

106.03 

7.05 

5.76 


Facility 

14.83 

249.13 

134.15 

383.27 

18.44 

20.82 

437.37 


Facility 

14.83 

180.21 

97.04 

277.25 

^3- 

CO 

15.06 

325.58 

No. 

solvent 

mixers 

— 

- 

m 

"3- 

— 

— 

r-~ 

No. 

solvent 

mixers 

- 

- 

m 


- 

— 

r- 

Baseline 

percent 

recovery 

85% 

70% 

0% 

|| Total Plant B 

85% 

0% 

Total nationwide 

Baseline 

percent 

recovery 

£ 

oo 

70% 

0% 


85% 

o 

Total nationwide 

Control device 

Condenser 

Condenser 

None 

Carbon adsorber 

None 

Control device 

Condenser 

Condenser 

None 


Carbon adsorber 

None 

Solvent 

used 

Toluene 

n-Hexane 

n-Hexane 

TCE 

Toluene 

Solvent 

used 

Toluene 

n-Hexane 

n-Hexane 


TCE 

Toluene 

Facility 

Plant A 

Plant B 

Plant C u 

| Plant D 

Facility 

Plant A 

Plant B 

Total Plant B 

!3 

u 

■*—> 

c 

C3 

CL, 

Plant D 


B-4 


At Plant C, estimated 85 percent control at solvent mixer; control efficiency is 94 percent; capture efficiency unknown, assumed to be 90 percent. 






























































The uncontrolled emissions for Plant B were back-calculated from the baseline emissions using 

information provided by the facility on equipment ratios for their production lines and on their 

solvent recovery system. Of the uncontrolled emissions, 35 percent of the emissions are estimated 

to be emitted from the Ross mixers line and 65 percent from the Sigma mixer line. 1 For each mixer 

line, 80.5 percent of emissions are estimated to be emitted from the mixer itself and 19.5 percent 

of the emissions are estimated to be emitted from the rest of the line (10.5 percent from extruder, 

>» 

7.2 percent from granulator, 1 6 percent from dryers, and 0.2 percent from hot presses). 1 


Based on information from the facility, the Sigma mixer is equipped v/ith a solvent recovery 

% 

system, the rest of the Sigma mixer line (extruder, granulator, dryers, and hot presses) is 

uncontrolled, and the Ross mixers line is also uncontrolled. 1 The solvent is drawn out of the 

mixed material from the Sigma mixer by vacuum. 2 The facility estimates that the residual solvent 

content is 10 percent, which means that 90 percent of the solvent is captured from the mixture. 1 

The solvent vapors are collected by a non-contact Freon-cooled condenser, which cools the 

solvent vapor to 60 o F. ! According to the facility, the condenser is 80 percent efficient in 

recovering the captured solvent. 2 The total solvent recovery is estimated at 70 percent recovery 

on average. These data were based on informal mass balance measurements performed by the 

facility personnel for facility purposes. Using this facility information, the total uncontrolled 

emissions were estimated using the following equation: 

Baseline emissions (556.45 tpy) = (0.35 * x) + [(0.65 * 0.805 * 0.30 * x) + 

(0.65 * 0.195 * x)], w'here x is total uncontrolled emissions. Solving for x, total 
uncontrolled emissions = 878.06 tpy. 

The uncontrolled emissions were broken out for the Sigma mixer line using the following 
equations: 

Uncontrolled emissions (Sigma mixer) = (0.65 * 0.805 * 878.06 tpy) = 459.45 tpy. 
Uncontrolled emissions (extruder, granulator, dryers, and hot presses) = 

(0.65 * 0.195 * 878.06 tpy) =111.29 tpy. 

The uncontrolled emissions were broken out for the Ross mixers line using the following 
equations: 

Uncontrolled emissions (Ross mixers) = (0.35 * 0.805 * 878.06 tpy) = 247.39 tpy. 
Uncontrolled emissions (extruder, granulator, dryers, and hot presses) = 

(0.35 * 0.195 * 878.06 tpy) = 59.93 tpy. 


B-5 


Based on 70 percent solvent recovery, the baseline (controlled) emissions for the Sigma mixer 
were estimated to be 0.3 * 459.45 tpy = 137.83 tpy. The baseline emissions for the Ross mixers 
line and the rest of the Sigma mixer line (extruder, granulator, dryers, and hot presses) are the 
same as the uncontrolled emissions because there is no solvent recovery for these equipment. 

B.2.2 MACT Floor and Beyond-the-Floor Emissions 

To comply with the MACT floor option (70 percent solvent recovery for solvent mixers), Plant B 
is expected to equip its uncontrolled Ross mixers with a solvent recovery system (condenser) 
capable of achieving 70 percent solvent recovery (including capture and collection). Therefore, 
the emissions associated with the MACT floor option for Plant B were estimated based on a 
70 percent reduction in uncontrolled emissions for the Ross mixers (0.3 * 247.39 tpy = 74.22 tpy). 
The emissions for the rest of the Ross mixers line and the entire Sigma mixer line would remain at 
baseline levels. 

• 

To comply with the beyond-the-floor option (85 percent solvent recovery for solvent mixers), 

Plant B is expected to equip its Sigma mixer and Ross mixers with solvent recovery systems 
(condensers) capable of achieving 85 percent solvent recovery (including capture and collection). 
Therefore, the emissions associated with the beyond-the-floor option for Plant B were estimated 
based on an 85 percent reduction in uncontrolled emissions for the Sigma mixer and Ross mixers 
(0.15 * 459.45 tpy + 0.15 * 247.39 tpy = 106.03 tpy). The emissions for the rest of the Sigma 
mixer line and Ross mixers line would remain at baseline levels. 

B.3 PlantC 

B.3.1 Baseline and Uncontrolled Emissions 

Uncontrolled emissions from Plant C were determined based on the annual consumption of 
trichloroethylene solvent, assuming that the quantity of solvent consumed is equal to the quantity of 
solvent emitted. According to the ICR response for Plant C, the annual consumption of 
trichloroethylene solvent for 1997 was expected to be 9,660 gal, and the HAP content of the 
solvent is 100 percent; this is equivalent to an annual consumption of 58.39 tpy for 


B-6 


trichloroethylene, based on a reported density of 12.09 lb/gal. 3 Therefore, the total uncontrolled 
emissions for Plant C were estimated to be 58.39 tpy. 

Using the equipment ratios from Plant B as a model (80.5 percent from solvent mixer, 10.5 percent 

from extruder, 7.2 percent from granulator, 1.6 percent from dryers, and 0 2 percent from hot 

presses), 80.5 percent of the uncontrolled emissions at Plant C were assumed to be from the 

solvent mixer. Emissions from the hot press were assumed to be equivalent to the total emissions 

from the extruder and dryer (10.5 percent +1.6 percent = 12.1 percent) because of the press’ 

relative position in the process and because it is heated. Emissions from the oven were assumed 

% 

to be equivalent to the remainder of the emissions (7.4 percent). The r efore, the uncontrolled 
emissions for the solvent mixer were estimated to be 0.805 * 58.39 tpy = 47.00 tpy, while the 
uncontrolled emissions for the rest of the solvent mixer line (hot press and oven) were estimated to 
be 0.195 * 58.39 tpy = 11.39 tpy. 

Baseline emissions for the solvent mixer were estimated based on the effectiveness of the vacuum 
system used to capture and collect the trichloroethylene solvent and the control efficiency of the 
carbon adsorber used to recover the trichloroethylene solvent. Based on information from Plant C, 
the control efficiency of the carbon adsorber is 94 percent. 4 No data are available on the 
effectiveness of the vacuum system at removing the trichloroethylene solvent from the mixed 
material. However, if the residual solvent content is similar to those at Plant B and Plant A (i.e., 
between 5 and 10 percent), the overall solvent recovery for the solvent mixer would be between 
85 and 90 percent. To be conservative, a solvent recovery of 85 percent was assumed. Therefore, 
baseline emissions for the solvent mixer were estimated to be 0.15 * 47.00 tpy = 7.05 tpy. 

Because the rest of the solvent mixer line (hot press and oven) is uncontrolled, the emissions from 
thes^ pieces of equipment would remain unchanged (11.39 tpy). 


B.3.2 MACT Floor and Beyond-the-Floor Emissions 

The MACT floor and beyond-the-floor emissions for Plant C would be identical to baseline 
emissions because the solvent mixer at this facility is assumed to already achieve 85 percent 


B-7 


solvent recover}'. Therefore, this solvent mixer is not impacted at the MACT floor and beyond- 
the-floor. 

B.4 Plant D 

B.4.1 Baseline and Uncontrolled Emissions 

Uncontrolled emissions from Plant D were determined based on the annual consumption of toluene 

solvent, assuming that the quantity of solvent consumed is equal to the quantity of solvent emitted. 

According to the ICR response for Plant D, the annual consumption of toluene solvent for 1997 

was expected to be 13,069 gallons, and the HAP content of the solvent is 100 percent; this is 

% 

equivalent to an annual consumption of 47.70 tpy for toluene, based on a reported density of 7.3 
lb/gal for toluene. 7 Therefore, the uncontrolled emissions for Plant D were estimated to be 
47.70 tpy. 

Using the equipment ratios from Plant B as a model (80.5 percent from solvent mixer, 10.5 percent 
from extruder, 7.2 percent from granulator, 1.6 percent from dryers, and 0.2 percent from hot 
presses), 80.5 percent of the emissions at Plant D were assumed to be from the solvent mixer. 
Because Plant D has no granulator, ratios were used to apportion the granulator emissions to the 
extruder (16.1 percent), dryer (2.9 percent), and hot press (0.5 percent). Therefore, the 
uncontrolled emissions for the solvent mixer were estimated to be 0.805 * 47.70 tpy = 38.40 tpy, 
while the uncontrolled emissions for the rest of the solvent mixer line (extruder, dryer, and hot 
press) were estimated to be 0.195 * 47.70 tpy = 9.30 tpy. 

B.4.2 MACT Floor and Beyond-the-Floor Emissions 

To comply with the MACT floor option (70 percent solvent recovery for solvent mixers). Plant D 
is expected to equip its uncontrolled solvent mixer with a solvent recovery system (condenser) 
capable of achieving 70 percent solvent recovery (including capture and collection). Therefore, 
the emissions associated with the MACT floor option for Plant D were estimated based on a 
70 percent reduction in uncontrolled emissions for the solvent mixer (0.3 * 38.40 tpy = 11.52 tpy). 
The emissions for the rest of the solvent mixer line would remain at baseline levels (9.30 tpy). 


B-8 


To comply with the beyond-the-floor option (85 percent solvent recovery for solvent mixers), 

Plant D is expected to equip its uncontrolled solvent mixer with a solvent recovery system 
(condenser) capable of achieving 85 percent solvent recovery (including capture and collection). 
Therefore, the emissions associated with the beyond-the-floor option for Plant D were estimated 
based on an 85 percent reduction in uncontrolled emissions for the solvent mixer (0.15 * 38.40 tpy 
= 5.76 tpy). The emissions for the rest of the solvent mixer line would remain at baseline levels 
(9.30 tpy). 


B.5 References 

% 

1. Completed information collection request for Plant A. 

2. Memorandum from Bullock, D., Midwest Research Institute, to Cavender, K., EPA/ESD. 
Site Visit Report Plant-A. 

3. Completed information collection request for Plant B. 

4. Memorandum from Schmitt, D., Bullock, D., and Abraczinskas, M., Midwest Research 
Institute, to Cavender, K., EPA/ESD. Site Visit Report-Plant B. 

5. Completed information collection request for Plant C. 

6. Memorandum from Abraczinskas, M., Bullock, D., Holloway, T., and Turner, M., Midwest 
Research Institute, to Cavender, K., EPA/ESD. August 3, 2001. Summary of Emission 
Test Data. 

7. Completed information collection request for Plant D. 


B-9 


TECHNICAL REPORT DATA 


1. REPORT NO. 2. 

EPA-453/R-01-008 

3. RECIPIENT'S ACCESSION NO. 

4. TITLE AND SUBTITLE 

National Emission Standards for Hazardous Air Pollutants 
(NESHAP) for the Friction Materials Manufacturing Industry- 
Background Information Document 

5. REPORT DATE 

August 2001 

6. PERFORMING ORGANIZATION CODE 

7. AUTHOR(S) 

8. PERFORMING ORGANIZATION REPORT NO. 

9. PERFORMING ORGANIZATION NAME AND ADDRESS 

Midwest Research Institute 

5520 Dillard Road, Suite 100 

Cary, NC 27511 

10. PROGRAM ELEMENT NO. 

11. CONTRACT/GRANT NO. 

68-D6-0012 

12. SPONSORING AGENCY NAME AND ADDRESS 

Office of Air Quality Planning and Standards* 

U. S. Environmental Protection Agency 

Research Triangle Park, NC 27711 

13. TYPE OF REPORT AND PERIOD COVERED 

Final (1997-2001) 

14. SPONSORING AGENCY CODE 

15. SUPPLEMENTARY NOTES 

16. ABSTRACT 

National emission standards for hazardous air pollutants (NESHAP) for friction materials manufacturing 
facilities are being proposed under the authority of Section 112(d) of the Clean Air Act as amended in 

1990. These standards would reduce air toxics from all major source friction materials manufacturing 
facilities (defined as those sources that emit or have the potential to emit 10 tpy or greater of individual 
HAPs, or 25 tpy or gfeater of any combination of HAPs). This document contains background 
information and environmental and cost impact assessments of the emission control options considered in 
developing the proposed standards. 

17. KEY WORDS AND DOCUMENT ANALYSIS 

a. DESCRIPTORS 

b. IDENTIFIERS/OPEN ENDED TERMS 

c. COSATI Field/Group 

n-Hexane 

Solvent mixer 

Solvent recovery 

Toluene 

Trichloroethylene 

Air pollution control 

Friction materials manufacturing 
Hazardous air pollutants 

MACT 

NESHAP 


18. DISTRIBUTION STATEMENT 

Release Unlimited 

19. SECURITY CLASS ( Repon , 

Unclassified 

21. NO. OF PAGES 

20. SECURITY CLASS (Page) 

Unclassified 

22. PRICE 


EPA Form 2220-1 (Rev. 4-77) 


PREVIOUS EDITION IS OBSOLETE 






































































































































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